Nolan v. Little

196 S.W.3d 1 (2004)

From our private database of 46,100+ case briefs, written and edited by humans—never with AI.

Nolan v. Little

Arkansas Supreme Court
196 S.W.3d 1 (2004)



C. D. Nolan (plaintiff) filed a request pursuant to Arkansas’s open-records law seeking various seed samples from the state’s plant board. The plant board received seeds from different seed dealers and farmers, and it performed germination and purity tests as part of its regulatory activity. Darryl Little (defendant), the director of the plant board, denied Nolan’s request. In his denial, Little maintained that seed samples were not public records. Nolan challenged Little’s determination and filed a complaint in circuit court. At trial, Nolan testified that he was an agricultural lawyer who represented various seed companies. Nolan’s request was initiated on behalf of his clients who were attempting to eliminate the illegal reproduction and sale of their seeds. A representative of the plant board also testified at trial and explained the testing procedure for seed samples. The representative described how the data from the seed samples was compiled into analysis reports. The representative also stated that the analysis reports were subject to disclosure under the open-records law. Little also testified at trial, explaining that he provided Nolan with numerous records related to his open-records request; however, Little did not provide the seed samples because he did not believe they qualified as a public record. In support of his position, Little asserted that the seed samples were not a compilation of data or information, but rather a physical sample that was utilized to compile the analysis reports. Little also stated that releasing any portions of the seed samples would result in their depletion and that the plant board would no longer be able to use them. The trial court found in favor of Little, and Nolan filed an appeal. On appeal, Nolan maintained that under Arkansas’s open-records law, a public record was defined to include “writings, recordings, sounds, film, tapes, electronic or computer-based information, or data compilations in any medium required to be kept” and that the term medium had to be interpreted to include seed samples and the genetic information contained therein. Nolan further asserted that the rules of statutory construction required that the term medium be broadly defined. The court of appeals affirmed the circuit court’s determination, and Nolan again filed an appeal.

Rule of Law


Holding and Reasoning (Dickey, C.J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 744,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 744,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,100 briefs, keyed to 987 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 744,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,100 briefs - keyed to 987 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership