Lazar Styles and Christine Styles v. Dallas County, Arkansas; Arkansas Public Entities Risk Management Association; Steven Beaver; And Chris Sanders

── Lazar Styles and Christine Styles v. Dallas County, Arkansas; Arkansas Public Entities Risk Management Association; Steven Beaver; And Chris Sanders ── Court: Court of Appeals of Arkansas Date: April 15, 2026 Category: General Cite as 2026 Ark. App. 233 ARKANSAS COURT OF APPEALS DIVISION III No. CV-24-742 Opinion Delivered April 15, 2026 LAZAR STYLES AND CHRISTINE STYLES APPEAL FROM THE DALLAS APPELLANTS COUNTY CIRCUIT COURT [NO. 20CV-19-22] V. HONORABLE SPENCER H. DALLAS COUNTY, ARKANSAS; SINGLETON, JUDGE ARKANSAS PUBLIC ENTITIES RISK AFFIRMED MANAGEMENT ASSOCIATION; STEVEN BEAVER; AND CHRIS SANDERS APPELLEES CASEY R. TUCKER, Judge Lazar Styles and Christine Styles1 (“Styles”) appeal the Dallas County Circuit Court’s grant of summary judgment to appellees, Dallas County, Arkansas; Arkansas Public Entities Risk Management Association (“APERMA”); Steven Beaver; and Chris Sanders (collectively, “Dallas County”). On appeal, Styles argues the circuit court erred in granting Dallas County’s motion for summary judgment and erred in denying his cross-motion for summary judgment. We affirm. I. Procedural History and Facts 1 Christine Styles originally claimed loss of consortium, but that claim is not an issue on appeal.  On March 27, 2017, Styles chose to engage in community-service work to pay off his court-ordered fees. He was assigned to work with the Dallas County landfill as a “trash thrower” on a garbage truck owned by Dallas County and operated by its employees, Steven Beaver and Chris Sanders. During the performance of his community service, while riding on a sidestep of the garbage truck, Styles’s left arm was crushed in the garbage truck’s compacting machine, resulting in a degloving injury. On April 22, 2019, Styles filed a complaint in the Dallas County Circuit Court against Dallas County, Arkansas; APERMA; and John Does 1–6. Styles alleged the Dallas County employees’ negligence led to Styles’s injury. APERMA was named as a party since it was “the insurer for negligence by Dallas County” and given that “counties are ‘immune from liability and from suit for damages except to the extent that they may be covered by liability insurance.’” In his original complaint, Styles sought compensatory damages and injunctive relief. Dallas County and APERMA filed an answer denying the allegations in the complaint and asserting affirmative defenses of tort immunity pursuant to Arkansas Code Annotated section 21-9-301 (Repl. 2022) and comparative fault. On October 1, 2019, Dallas County and APERMA moved for summary judgment, alleging that as a public entity, Dallas County and its employees were entitled to sovereign immunity. While Dallas County had an agreement with APERMA for limited coverage of bodily injury, APERMA’s policy specifically excluded claims barred by sovereign or tort immunity. Dallas County argued that “the Arkansas direct-action statute does not apply as a 2 bar to sovereign immunity extended by Ark. Code Ann. § 21-9-301” and that summary judgment was thus proper. Styles filed an amended complaint adding Steven Beaver, in his capacity as an employee of Dallas County, and alleging Beaver negligently drove and operated the garbage truck, thereby causing the degloving of Styles’s hand. Specifically, Styles alleged Beaver activated the compacting mechanism while Styles’s arm was inside the garbage compactor. On March 16, 2020, Styles filed a second amended complaint adding Chris Sanders as a defendant. Styles alleged that Sanders, as his supervisor, failed to train him regarding the proper safety procedures for working on a garbage truck and failed to exercise ordinary care by assigning him to