The Legal Landscape in the Post Parkland Era

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December 6, 2018
Marshall S. Ney
The Legal Landscape in the
Post Parkland Era

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Threats and the First
Amendment

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General Rule
“School officials cannot constitutionally reach
out to discover, monitor, or punish any type of
out of school speech.” D.J.M. v. Hannibal Pub.
Sch. Dist., 647 F.3d 754 (8th Cir. 2011).

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Exceptions
Courts have recognized two free speech exceptions
pertaining to off-campus remarks made by students:
-“True Threats”
-“Substantial Disruptions”
See Watts v. United States, 394 U.S. 705 (1969); Tinker v. Des
Moines Indep. Cmty. Sch. Dist., 393 U.S. 503 (1969).

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The “True Threat” Exception
In Doe v. Pulaski Cnty. Special Sch. Dist., a
“true threat” was defined as a “statement that a
reasonable recipient would have interpreted as
a serious expression of an intent to harm or
cause injury to another.” 306 F.3d 616 (8th Cir.
2002).
If a student, on or off-campus, makes a true
threat, their remarks are not protected by the
First Amendment. Discipline for remarks
amounting to a true threat is not a violation of an
individual’s First Amendment rights.

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8th Circuit “True Threat” Factors
When determining whether statements have constituted threats of
force, the 8th Circuit has considered the following factors:
- The reaction of the recipient of the threat and of other listeners;
- Whether the threat was conditional;
- Whether the threat was communicated directly to its victim;
- Whether the maker of the threat had made similar statements to the victim in
the past; and
- Whether the victim had reason to believe that the maker of the threat had a
propensity to engage in violence.
The court noted that this list is not exhaustive and the presence or
absence of any one of these elements is not dispositive.
United States v. Dinwiddie, 76 F.3d 913 (8th Cir. 1996).

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The “Substantial Disruption”
Exception
In Tinker v. Des Moines Indep. Cmty. Sch. Dist., the
court created the “substantial disruption” exception to
determine whether certain speech or expressions were
given protection under the First Amendment. 393 U.S.
503 (1969).
The test asks whether it was reasonably foreseeable
that the speech or expression by the student “would
cause school officials to reasonably anticipate
substantial disruption of or material interference with”
the work of the school. Boim v. Fulton Cty. Sch. Dist.,
494 F.3d 978 (11th Cir. 2007) (Judge Black concurring
and fully articulating the rule set forth in Tinker).

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Vilonia School District v. S. et al
• On March 1, 2018, A.R.S., a student in the district, posted a photo of himself
holding a handgun on Snapchat. The photo showed A.R.S. with his finger on the
gun’s trigger with the hashtag “#ILOVEITWHENTHEYRUN.”
• A.R.S. also posted videos acting like he was shooting the gun and talking about
killing. The video showed the word “kill.” He additionally posted a photo of some
classmates with the head of one of the classmates circled in red.
• Another video was posted by A.R.S. of himself with a handgun stating, “I don’t
fight to hurt – I fight to kill.”
• A.R.S. admitted to the District special education director that he was depressed
and almost killed himself by hanging, an incident that was also documented on
Snapchat with a photo showing A.R.S. with a belt around his neck.
• In light of these events, a concerned student in turn revealed a previous
discussion in which A.R.S. stated, “I just want to fight someone and end up killing
them and go to prison for the rest of my life.”

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Vilonia School District v. S et al
• On March 6, 2018, A.R.S. was suspended from school for ten days and
was recommended for expulsion. The District, however, cannot
maintain the suspension for an extended length of time because A.R.S.
is not subject to the District’s discipline policy because he receives
special education services pursuant to his Individualized Education
Program.
• On March 13, 2018, A.R.S.’s parents filed a due process complaint.
• Vilonia School District subsequently filed a complaint seeking a
temporary restraining order and preliminary and permanent injunction
on March 23, 2018.
• Judge Baker granted a modified preliminary injunction on April 11, 2018,
placing A.R.S. on home-bound setting for school.
• Vilonia Sch. Dist. V. S et al, Docket No. 4:18-cv-00219 (E.D. Ark. March
27, 2018).

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Vilonia School District v. A.R.S. et al.
• The hearing officer who heard this case under the ADE Special
Education Unit agreed with Parents about the placement of A.R.S. and
ordered that A.R.S. receive special education services at the previously
agreed upon location as contained in his amended IEP of October 25,
2017.
• According to his previous IEP, A.R.S.’s placement was in the general
education setting 98 percent of school time per week.
• The Court then ruled that “[w]hen a state appointed hearing officer in a
due process hearing ‘agrees with the child’s parents that a change of
placement is appropriate, that placement must be treated as an
agreement between the State and the parents.’”
**Translation – the Student goes back to school.
Vilonia Sch. Dist. V. S et al, Docket No. 4:18-cv-00219 (E.D. Ark. March 27,
2018).

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McKinney v. Huntsville School
District et al
• A student, K.P., posted a photo of himself to his
private Instagram account. K.P. was depicted
holding an AR-15 with no accompanying words.
• Other students who had seen the photo posted
comments that implied a school shooting motif.
The next morning K.P. deleted the post.
• Huntsville Police department investigated the
situation and determined K.P. was not a threat.
K.P. claimed to have posted the photo to emulate
a 1920’s picture of a man with a tommy-gun.

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District et al
• On February 27, 2018, K.P. was suspended from school for 10
days for terroristic threatening, with a recommendation for
expulsion for 365 days.
• On March 5, 2018, K.P. was expelled for 365 days with loss of
academic credit.
• On April 26, 2018, a complaint was filed alleging, among other
counts, violation of K.P.’s First Amendment and Due Process
rights.
• K.P. sought a preliminary injunction to get back in school.
McKinney v. Huntsville Sch. Dist. et al, Docket No. 5:18-cv-05067 (W.D. Ark. April 26, 2018).

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District et al
The Court entered a written order on the
preliminary injunction motion on October 17,
2018.
What did he rule?

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District et al
Motion DENIED.

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District et al
“Given the totality of the
circumstances, it was
reasonably foreseeable that
such comments would cause
a substantial disruption to the
campus community.”

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Huntsville’s New Policy
Addendum:
Huntsville School District has a zero tolerance policy for any type of terroristic threatening relating to school
shootings, school bombings, or any other type of terroristic threatening pertaining to groups of students
and/or faculty and staff or a single student or faculty and staff this includes those of implicit and explicit in
nature. This includes threats posted on social media sites, texts, emails, or any other type of internet
webpages as well as those done verbally and/or written during school hours and after school hours or when
school is not in session. Huntsville School District administration will seek the maximum discipline for these
types of threats, up to and including expulsion.
Students shall not wear the following types of clothing: trench coats, articles of clothing with logos or
writing that suggests school shooting, bombing, or threats of any kind on them because these can be seen
as an act of aggression and implying terroristic thoughts and ideals. It is our goal to provide a safe learning
environment for all students and faculty/staff.
Board Approved:
March 12, 2018

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Sagehorn v. Independent School
District No. 728
• An anonymous internet post on a website titled
“Rogers Confessions” asked, “did
@R_Sagehorn3 actually make out with [name of
female teacher at Rogers High School].”
• The student, Sagehorn, responded “actually yes”
off-campus and not using any school computers.
• Sagehorn was suspended and was subsequently
informed that he would be expelled if he did not
withdraw from the district, Sagehorn ultimately
withdrew.

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Sagehorn v. Independent School
District No. 728
The Court concluded that Sagehorn had
adequately pleaded a First Amendment claim
and found that the school district failed to show
that they were permitted to regulate his speech.
- Sagehorn’s remark did not amount to a “substantial
disruption” as required by Tinker.
- There was no demonstration that the speech was
lewd, vulgar, obscene, or harassing.
Sagehorn v. Indep. Sch. Dist. No. 728, 122 F.
Supp. 3d 842 (D. Minn. 2015).

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S. J. W. v. Lee’s Summit R-7
School District
• Two brothers, students at Lee’s Summit North High School, created a
website called NorthPress. The website contained a blog to discuss,
satirize, and “vent” about events at Lee’s Summit North.
• The brothers added posts to the blog containing a variety of offensive
and racist comments as well as sexually explicit and degrading
comments about particular female classmates, whom they identified by
name.
• The brothers only told a handful of friends about the website. However,
word spread quickly and unknown students began using school
computers to upload content to NorthPress.
• The school immediately suspended the brothers for ten days and
eventually suspended them both for 180 days.
• The brothers subsequently filed suit against the school district.

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S. J. W. v. Lee’s Summit R-7
School District
The court, in denying the brothers’ preliminary injunction,
determined that the students were unlikely to succeed on the
merits and found that the students’ posts on the website
caused a substantial disruption pursuant to Tinker:
- Numerous Lee’s Summit North computers were used to access
NorthPress;
- Teachers testified that they had experienced difficulty managing their
classes because students were distracted and in some cases upset
by NorthPress;
- Local media arrived on campus; and
- Parents contacted the school with concerns about safety, bullying,
and discrimination.
S. J. W. v. Lee’s Summit R-7 Sch. Dist., 696 F.3d 771 (8th
Cir. 2012).

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D.J.M. v. Hannibal Public School
District
• D.J.M., a student of the Hannibal Public School District, sent instant
messages from his home to a classmate in which he talked about
getting a gun and shooting some other students at school.
• The student identified a specific type of gun he could use and
expressed his access to weapons; listed individuals he planned to
shoot; discussed his suicide in connection with the potential school
shooting; and expressed that he wanted Hannibal “to be known for
something.”
• The classmate of D.J.M. and a trusted adult alarmed the principal and
authorities.
• D.J.M. was placed in juvenile detention and suspended for the
remainder of the school year.
• Parents subsequently brought this suit alleging violation of D.J.M.’s First
Amendment rights.

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D.J.M. v. Hannibal Public School
District
The court held that notifying law enforcement of D.J.M.’s threatening messages and his
subsequent suspension did not violate his First Amendment Rights.
- The court considered D.J.M.’s conduct to be a “true threat,” given:
- D.J.M.’s admitted depression;
- Expressed access to weapons; and
- Other specific statements.
- The court also held, alternatively, that D.J.M.’s expressions constituted a “substantial disruption”:
- Parents and students notified school authorities, expressing concerns about student safety and
asking what measures the school was taking to protect them;
- Parents and students inquired about a rumored “hit list” and who had been targeted; and
- School officials expended considerable time dealing with these concerns and ensuring that
appropriate safety measures were in place.
D.J.M. v. Hannibal Pub. Sch. Dist., 647 F.3d 754 (8th Cir. 2011).

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Riehm v. Engelking
• A student wrote a graphic essay expressing,
in detail, a plan to kill his English teacher and
himself.
• The murder was described “in gruesome
detail, including shattering [the teacher’s] eye
with a bullet and licking her blood from [the
student’s] lips.”
• Additionally, the student had previously
written two other troubling essays.

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Riehm v. Engelking
The court held that the student’s graphic essay
was a true threat and, thus, unprotected by the
First Amendment.
- The essay’s hate-filled “obsession with weapons and
gore” and its description of the teacher’s murder and
student’s suicide led “to the inescapable conclusion
that this was a serious threat.”
Riehm v. Engelking, 538 F.3d 952 (8th Cir.
2008).

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Neal v. Efurd
Students created a website with the following
content:
- An online comic depicting a faculty member shooting
two students; and
- A feature identified as “Bulldog Death of the Week,”
presumably in connection with the school’s mascot
which was a bulldog

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Neal v. Efurd
The court found that there was no “true threat”
present and that the students’ actions did not cause
any “substantial disruptions”:
- The court held that the comic did not suggest that the
speaker intended to shoot anyone, nor could it be
reasonably interpreted as a threat that a member of the
school administration might shoot someone.
- The court further held that the feature “Bulldog Death of the
Week” was so “abstract and underdeveloped” that no
visitor to the website could reasonably have understood it
to suggest that violence would be done to anyone at the
school.
Neal v. Efurd, No. 04-CV-2195, 2005 BL 88660
(W.D. Ark. Feb. 18, 2005).

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Doe v. Pulaski County Special
School District
• A student, K.G., was given a letter which was
authored by another student and former boyfriend,
J.M. In the letter, J.M. expressed a “pronounced,
contemptuous and depraved hate” for K.G. and
referred to her as a “bitch,” “slut,” “ass,” and a
“whore.” The letter used graphic language and spoke
about J.M.’s desire to “sodomize, rape, and kill” K.G.
• Another student present during K.G.’s reading of the
letter reported it to a school resource officer. The
resource officer responded immediately and found
K.G. “frightened and crying.”
• After the school administration learned about the
letter, J.M. was suspended.

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Doe v. Pulaski County Special
School District
The court concluded that expulsion of J.M. did not violate his First
Amendment rights because the letter contained true threats.
- The court held that a reasonable recipient would have perceived J.M.’s letter
as a serious expression of intent to harm K.G., thus the letter amounted to a
true threat.
- J.M. had previously discussed the content of the letter and had
additionally shown violence towards animals.
- The court noted that the speaker must additionally have intended to
communicate his threat to another. This is satisfied if the “speaker
communicates the statement to the object of the purported threat or to a
third party.”
- J.M. permitted a friend to read the letter, and had discussed the letter with
multiple people.
Doe v. Pulaski Cty. Special Sch. Dist., 306 F.3d 616 (8th Cir. 2002).

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Jones v. State
• A student became angered when a girl in
school would not reply to notes he had given
her in a class.
• The student then wrote a rap lyric and gave it
to the girl. The lyric threatened to murder the
girl and her family.
• The principal and Fayetteville Police
Department were notified about the letter.

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Jones v. State
The court held that the student’s lyric constituted a true threat to the
girl, and that discipline in accordance with the incident did not
violate First Amendment rights. In reaching their decision, the court
adopted and applied the factors from Dinwiddie:
- The girl had an immediate reaction to the threat. She left and reported the
incident to the principal, she was frightened and upset, and believed that the
student was capable of carrying out the threat because he had a criminal
record and also knew where her family lived.
- The threat the student made was not conditional.
- The student directly communicate the threat to the girl by handing the note
to her.
- The student had not made similar statements in the past, but he did have a
criminal history.
Jones v. State, 64 S.W.3d 728 (Ark. 2002).

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Wynar v. Douglas County School
District
• A student that frequently exchanged messages on MySpace began
detailing to his friends his plans to carry out a school shooting on April
20—Hitler’s birthday and the anniversary of the Columbine massacre.
• The student collected weapons and ammunition and reported owning
various rifles.
• The friends became increasingly concerned about his repeated threats
to carry out the shooting. The student had specified who he would
shoot, how he would kill them, and the guns he might use.
• The friends approached their football coach and together reported the
incidents to the principal.
• The student was interviewed and suspended for ten days. The school
board eventually expelled him for 90 days.
• The student and his father filed suit.

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Wynar v. Douglas County School
District
The court held there was no violation of the
student’s First Amendment rights.
- “The nature of the threats here was alarming and
explosive. Confronted with a challenge to the safety of its
students, Douglas County did not need to wait for an actual
disruption to materialize before taking action.”
- “It was reasonable for Douglas County to interpret the
messages as a real risk and to forecast a substantial
disruption.”
Wynar v. Douglas Cty. Sch. Dist., 728 F.3d 1062
(9th Cir. 2013).

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J.S. ex rel. Snyder v. Blue
Mountain School District
• An honor roll eighth grade student created a fake
MySpace profile of the principal, on which she
accused the principal of hitting on students and
parents and having sex in his office.
• The profile was limited in access to the student
and her friends and was never taken seriously or
viewable at school.
• The profile did contain the principal’s picture, but
did not identify him by name, school, or location.
• The student was suspended for creating the
profile.

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J.S. ex rel. Snyder v. Blue
Mountain School District
The court held that the student’s First Amendment
rights were violated when it suspended her for free
speech that caused no substantial disruption in
school and that could not reasonably have led
school officials to forecast substantial disruption.
- “[B]eyond general rumblings, a few minutes of talking in
class, and some officials rearranging their schedules to
assist [the principal] in dealing with the profile, no
disruptions occurred.”
J.S. ex rel. Snyder v. Blue Mountain Sch. Dist., 650
F.3d 915 (3d Cir. 2011).

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Layshock v. Hermitage School
District
• A high school senior—using his grandmother’s
computer—created a fake profile of his principal,
where he posted that the principal used steroids,
smoked marijuana, and was an alcoholic.
• The joke led to other students making similar
profiles and school disciplinary action against
those students.
• The school suspended the student, placed him in
an alternative education program, and banned
him from certain activities.

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Layshock v. Hermitage School
District
The court determined that the school’s response
transcended the protection of free expression which
our First Amendment guarantees. In coming to its
conclusion, the court reasoned:
- The district could not establish a sufficient connection
between the student’s conduct and the school
environment’s substantial disruption;
- The First Amendment could not be applied so far as to
expressive conduct that was engaged in off-campus; and
- The student’s use of the districts website to obtain
information did not constitute entering the school.
Layshock v. Hermitage Sch. Dist., 650 F.3d 205 (3d
2011).

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Kowalski v. Berkeley County
School
• A student created a MySpace group named
“Students Against Sluts Herpes” which was
dedicated to ridiculing one particular student.
The student also invited 100 other students at
the high school to join the group.
• The targeted student discovered the page and
refused to attend class.
• Administrators suspended the student that
created the page for five days and imposed a
90-day social suspension.

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Kowalski v. Berkeley County
School
The court concluded that the school was authorized to
discipline the student because her speech interfered
with the work and discipline of the school and, thus, was
not a violation of the student’s First Amendment rights.
- Although the student’s speech started off school grounds, the
page was designed to bully and harass another student by
generating chatter among “invited” students at the high school.
- “It was foreseeable in this case that Kowalski’s conduct would
reach the school via computers, smartphones, and other
electronic devices, given that most of the “S.A.S.H.” group’s
member and the target of the group’s harassment were
Musselman High School students.”
Kowalski v. Berkeley Cty. Sch., 652 F.3d 565 (4th Cir.
2011).

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Wisniewski v. Weedsport Central
School District
• A student sent an instant message to some
friends, portraying an icon with a pistol
shooting a bullet and text about killing his
English teacher. This message was sent
outside of school.
• Another student discovered it and took the
instant message to the English teacher.
• School authorities notified the police,
suspended the student, and proposed a long
term suspension.

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Wisniewski v. Weedsport Central
School District
In applying the Tinker standard, the court held
that there was no violation of First Amendment
rights.
- The panel unanimously agreed that it had been
“reasonably foreseeable that the [instant messaging]
icon would come to the attention of the school
authorities and the teacher” and that it would “create a
risk of substantial disruption within the school
environment.”
Wisniewski v. Weedsport Central Sch. Dist.,
494 F.3d 34 (2d Cir. 2007).

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Porter v. Ascension Parish School
Board
• A student drew a sketch at home showing his
school under attack “by a gasoline tanker
truck, missile launcher, helicopter, and various
armed persons.”
• The sketch was placed in a closet where it
remained for two years until his younger
brother found it and took it to school.

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Porter v. Ascension Parish School
Board
The Fifth Circuit concluded that “because [the
student’s] drawing cannot be considered a true
threat as it was not intentionally communicated,
the state was without authority to sanction him
for the message it contained.”
Porter v. Ascension Parish Sch. Bd., 393 F.3d
608 (5th Cir. 2004).

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New Requirements to
Determine Threats
State Legislation on the
Horizon

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Developing State Laws
Emerging Arkansas legal requirements:
Behavior Threat Assessments Soon Will Be Required
“Reports or observations of potential threats to a school must be
investigated in an appropriate, timely and effective manner. Based on
information obtained, threat assessments determine how credible and
serious the threat is and to what extent the person has the resources,
intent and motivation to carry out the threat. If it is determined that there
is a risk of violence to a school and its students and staff, a plan to
manage or reduce the threat must be developed and implemented.”
-- Preliminary Report, Arkansas School Safety Commission

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The Threats Are Real In Our
Schools
According to the CDC, Arkansas ranks first in the nation among
high school students in these categories:
• Bullied (26.7%)
• Physically forced to have sexual intercourse (19.2%)
• Experienced sexual violence by anyone (18.5%)
• Experienced dating violence (12.1%)
• Felt sad or hopeless (40.2%)
• Seriously attempted suicide (23.2%)
• Made a plan about how to attempt suicide (26.1%)
• Took pain medication without a prescription (19.3%)

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Schools
According to the CDC, Arkansas ranks second in
the nation among high school students in these
categories:
• Threatened or injury with a weapon at school
(11.7%)
• In a physical fight at school (26.6%)
• Actually attempted suicide (15.8%)
• Used cocaine (9.4%)
• Injected an illegal drug (7.4%)

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Schools
According to the CDC, Arkansas ranks fourth in
the nation among high school students in this
category:
Electronically bullied

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Additional Issues
Potential Challenges with
Students Receiving Special
Education

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Violence in Schools
It is a balancing act…
Duty to
maintain a
safe and
orderly
campus
IDEA requires
schools to
serve all
students
appropriately,
including those
with disabilities
who commit
serious or
violent
offenses.

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Developing Conflicts in State
& Federal Laws
Current Federal legal requirements:
IDEA Restricts a School’s authority to unilaterally
remove a student receiving special education to
three (3) “special circumstances”:
1. Weapons
2. Drugs
3. Infliction of “serious bodily injury”

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Violence in Schools
“Special Circumstances” under 20 USC
1415(k)(1)(G)(i-iii)
• Under special circumstances, what does serious
bodily injury mean?
• Serious bodily injury involves a substantial risk of
death, unconsciousness, extreme physical pain,
protracted and obvious disfigurement, or protracted
loss or impairment of the function of a bodily member,
organ, or mental faculty, as defined in the U.S.
criminal code. [18 U.S.C. § 1365(h)(3)] These
definitions are incorporated by reference in the IDEA.

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Violence in Schools
Unfortunately it is not so straightforward in application
• A 2015 case in Michigan determined that a disabled
student who threw chairs at his teacher, adult
support, and students, bit his teacher in the leg,
through the jeans and drawing blood, and running
outside and retrieving a log which he intended to
use to break a window but instead hit his father
when he stepped in the way, did not rise to the level
of substantial bodily injury for the school to
unilaterally suspend the child for 45 days.Troy Sch. Dist. v. K.M.,
2015 U.S. Dist. LEXIS 40970 at *7 (E.D. Mich. 2015).

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Violence in Schools
Another case had a different result
• This year, a court determined that the initial 45
day suspension of a 17 year old student who
pushed a student to the ground and repeatedly
punched the student in the head resulting in the
student suffering a concussion, was appropriate.
The court further held that public interest weighs
strongly in favor of the school. Olu-Cole v. E.L. Haynes Pub. Charter
Sch., 292 F. Supp. 3d 413, 417 (D.D.C. 2018).

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Violence in Schools
• Ultimately, the Supreme Court has
acknowledged that suspension is a necessary
tool as well as a valuable one.Goss v. Lopez, 419 U.S. 565, 580 (1975).
• Soon, our own state will require us to determine
whether there is a risk of violence to a school
and its students and staff, and if so, to develop
and implement a plan to manage or reduce the
threat. Preliminary Report, Arkansas School Safety Commission.

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Developing Conflicts in State
& Federal Laws
But . . . .
identification of a student receiving
special education as an imminent
threat does not authorize a school to
remove the student if the threat is a
manifestation of the student’s
disability.

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Violence in Schools
So what can schools (currently) do?
Under IDEA Regulations there are seven things administrators can do:
• The school can seek parental agreement for a change of placement. If the school and
the parent agree, a change of scenery is easily accomplished through an IEP meeting.
• The school can propose a change of placement when the parent does not agree. The
district must be prepared to defend this proposal in a due process hearing, and the “stay
put” rule will likely keep the student in the current placement until that hearing runs
its course.
• If the school believes that a change of placement is urgently needed due to safety
concerns, and the parent will not agree, the school can seek an order via an expedited
hearing before a hearing officer or judge.
• The school can suspend a student from school, without any services, for up to 10
cumulative days during the school year.
• The school can report possible criminal activity to the police, consistent with how the
school would treat similar behavior by nondisabled students.
• The school can ask the IEP team to develop a behavior intervention plan for the
student with the goal of improving the student’s behavior.

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Violence in Schools
But . . . .
none of these options are
immediate.

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The Goal
Federal Legislative Change
and State Legislative
Clarification

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Amend the IDEA
Add a Fourth (4th) “Special Circumstance” to Allow
Unilateral Change of Placement
1. Weapons
2. Drugs
3. Infliction of “serious bodily injury”
4. Identification of a student as an imminent
threat to cause serious bodily injury

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Include in State Threat
Assessment Laws
• Clarity concerning how data and threat
assessments are maintained, with
recommendations for:
• Transferable to successive districts; and
• Obtainable from previous districts
• Mandate that law enforcement notify school
districts of juvenile criminal activities of students
zoned for the district.

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THANK YOU!!

www.FridayFirm.com
www.FridayFirm.com
400 West Capitol Ave. Suite 2000 I Little Rock, AR 72201
3425 North Futrall Dr. Suite 103 I Fayetteville, AR 72703
3350 South Pinnacle Hills Pkwy. Suite 301 I Rogers, AR 72758
MARSHALL S. NEY
Phone: 479-695-6049
Litigation I Partner
Email: mney@fridayfirm.com
Website: www.fridayfirm.com/attorney/mney

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