**STATE COURT COMPLAINT – BREACH OF CONTRACT

Arkansas Circuit Court Template**
[// GUIDANCE: Drafted for use in any Arkansas Circuit Court. Conforms to Arkansas Rules of Civil Procedure (“Ark. R. Civ. P.”). Insert county-specific and division-specific information where indicated.]

TABLE OF CONTENTS

1. Caption & Style of Cause
2. Preliminary Statement & Nature of Action
3. Parties
4. Jurisdiction & Venue
5. Statement of Facts
6. Cause of Action: Breach of Contract
7. Conditions Precedent / Performance Excused
8. Damages
9. Request for Injunctive Relief (Optional)
10. Demand for Jury Trial (Optional)
11. Prayer for Relief
12. Reservation of Rights
13. Verification (Optional)
14. Certificate of Service

1. CAPTION & STYLE OF CAUSE

IN THE CIRCUIT COURT OF [COUNTY] COUNTY, ARKANSAS
[CIVIL / COMMERCIAL / OTHER] DIVISION

[PLAINTIFF LEGAL NAME],
  Plaintiff,

v.                       Case No. [__]

[DEFENDANT LEGAL NAME],
  Defendant.

2. PRELIMINARY STATEMENT & NATURE OF ACTION

1. Plaintiff brings this action for monetary and equitable relief arising from Defendant’s material breach of a written contract dated [Contract Date] (the “Contract”).
2. The amount in controversy exceeds the mandatory jurisdictional minimum of this Court.
3. Injunctive relief is sought to prevent continuing and irreparable harm.

[// GUIDANCE: Arkansas follows notice pleading. Keep statements “short and plain” (Ark. R. Civ. P. 8(a)).]

3. PARTIES

4. Plaintiff: [Full Legal Name], a [Entity Type & State of Organization OR Individual], with its principal place of business / residence at [Address].
5. Defendant: [Full Legal Name], a [Entity Type & State of Organization OR Individual], with its principal place of business / residence at [Address].

4. JURISDICTION & VENUE

6. This Court has subject-matter jurisdiction over this action pursuant to Ark. Const. art. 7, § 11 and applicable statutes because the claims asserted are civil in nature and the amount in controversy exceeds [state monetary threshold, if any].
7. Personal jurisdiction is proper because Defendant transacted business in Arkansas and the events giving rise to the claims occurred in [County] County.
8. Venue is proper in this County under Ark. Code Ann. § 16-60-101 et seq. because [state venue basis—e.g., Defendant resides here, contract performed here, etc.].

5. STATEMENT OF FACTS

9. On [Contract Date], Plaintiff and Defendant entered into the Contract, attached as Exhibit A.
10. Plaintiff fully performed, or was ready, willing, and able to perform, all material obligations required under the Contract.
11. Beginning on or about [Date], Defendant failed to [describe specific breaches—e.g., deliver goods, remit payment] as required by Section [X] of the Contract.
12. Plaintiff provided written notice of breach to Defendant on [Date] and afforded Defendant the contractually-mandated [Number]-day cure period, which expired without cure.
13. As a direct and proximate result of Defendant’s breach, Plaintiff has sustained damages presently estimated at $[Amount], exclusive of interest, costs, and attorneys’ fees.

6. CAUSE OF ACTION – BREACH OF CONTRACT

14. Plaintiff realleges and incorporates Paragraphs 1–13 as if fully set forth herein.
15. The Contract is a valid, binding, and enforceable agreement supported by adequate consideration.
16. Defendant breached the Contract by [specific breach].
17. Defendant’s breach was material and not excused.
18. Plaintiff suffered foreseeable damages in an amount to be proven at trial.

7. CONDITIONS PRECEDENT / PERFORMANCE EXCUSED

19. All conditions precedent to Defendant’s performance have occurred, been performed, or have been waived.
20. To the extent any additional performance was required of Plaintiff, such performance has been excused by Defendant’s prior material breach.

8. DAMAGES

21. Plaintiff seeks:
     a. Compensatory damages in an amount not less than $[Amount];
     b. Pre- and post-judgment interest at the maximum lawful rate;
     c. Reasonable attorneys’ fees and costs as permitted by contract and Arkansas law; and
     d. Any other and further relief the Court deems just and proper.

[// GUIDANCE: Arkansas allows prejudgment interest on liquidated sums; ensure amount is “definitely ascertainable.”]

9. REQUEST FOR INJUNCTIVE RELIEF (OPTIONAL)

22. Plaintiff will suffer immediate and irreparable harm absent injunctive relief because monetary damages alone are inadequate to remedy [describe ongoing harm].
23. Plaintiff therefore requests preliminary and permanent injunctive relief enjoining Defendant from [specific conduct] and compelling specific performance of the Contract.

[// GUIDANCE: Include verified complaint and/or supporting affidavit for ex parte TRO. Comply with Ark. R. Civ. P. 65.]

10. DEMAND FOR JURY TRIAL (OPTIONAL)

24. Pursuant to Ark. R. Civ. P. 38(a), Plaintiff hereby demands a trial by jury on all issues so triable.

11. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in its favor and award:

A. Compensatory damages in an amount to be determined at trial but not less than $[Amount];
B. Pre- and post-judgment interest;
C. Reasonable attorneys’ fees and costs;
D. Preliminary and permanent injunctive relief as set forth above; and
E. Such other and further relief as the Court deems just and proper.

12. RESERVATION OF RIGHTS

Plaintiff reserves the right to amend this Complaint to assert additional claims or parties as discovery proceeds, in accordance with Ark. R. Civ. P. 15.

13. VERIFICATION (OPTIONAL)

[PLAINTIFF REPRESENTATIVE NAME], being duly sworn, states that he/she has read the foregoing Complaint and that the facts stated therein are true and correct to the best of his/her knowledge, information, and belief.

______
        [NAME, TITLE]
        For Plaintiff

Subscribed and sworn before me this ___ day of __, 20__.

Notary Public
My Commission Expires: ______

[// GUIDANCE: Verification is not required for contract claims but may expedite injunctive relief.]

14. CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Complaint was served upon the following by [method—e.g., certified mail, hand delivery, electronic service pursuant to Ark. R. Civ. P. 5] on this ___ day of __, 20__:

• [Opposing Counsel / Defendant] – [Address / Email]

[ATTORNEY NAME]
Ark. Bar No. [__]
[Law Firm Name]
[Address]
[Phone] | [Email]
Counsel for Plaintiff

PRACTICE NOTES & STATE-SPECIFIC COMPLIANCE

[// GUIDANCE:
1. Pleading Requirements – Arkansas uses notice pleading; attach contract as Exhibit A.
2. Service Rules – Rule 4 requires service within 120 days; use sheriff, deputy sheriff, or authorized process server. Include summons when filing.
3. Discovery Limits – Arkansas imposes no automatic numerical limits on interrogatories or depositions; parties can stipulate or move for protective orders under Rules 26 & 30.
4. Mandatory Confidential-Info Redaction – Remove SSNs, financial account numbers, and other sensitive data per Administrative Order 19.
5. Filing Fees & Cover Sheet – Submit a Civil Case Cover Sheet and pay county filing fee at the time of filing.
6. Electronic Filing – If the county participates in eFlex, register counsel and file electronically.
7. Rule 11 Signature – Ensure the attorney’s signature block complies with Ark. R. Civ. P. 11.
]

END OF TEMPLATE