Justia Louisiana Supreme Court Opinion Summaries

An employee working as a mechanic suffered a back injury at work in June 2020 but did not initially lose wages because his employer moved him to a light-duty position with full salary. After more than two years, the employer eliminated the light-duty position and stopped paying his salary. At that point, the employer began paying the employee temporary total disability benefits for approximately two years. When those benefits stopped in March 2024, the employee filed a disputed claim for compensation in July 2024, more than four years after the original injury.The employer responded before the Office of Workers' Compensation (OWC), District 2, by raising an exception of prescription, arguing the claim was filed outside the one-year period allowed by Louisiana law. The OWC judge denied the exception, finding that the employer’s initiation and continuation of disability benefit payments well after the prescriptive period had run was a clear renunciation of prescription. The employer sought supervisory review from the Louisiana Court of Appeal, which denied relief. The employer then applied for a writ to the Supreme Court of Louisiana, which was granted.The Supreme Court of Louisiana held that, under Louisiana’s Workers’ Compensation Law, the prescriptive period for filing a claim is not tolled merely because the employee initially continues to earn full wages. However, the Court further held that when an employer initiates and continues regular workers’ compensation payments after the prescriptive period has run, such conduct constitutes a tacit renunciation of prescription. This means the employer waives the right to assert prescription as a defense. Therefore, the Court affirmed the OWC’s denial of the employer’s exception of prescription and remanded the matter for further proceedings. View "Johnson v. AECOM Amentum Government Services" on Justia Law

The underlying dispute arose after an individual was convicted of a crime in Louisiana, served part of his sentence, and later had his conviction reversed or vacated. Claiming factual innocence, he sought compensation under Louisiana’s wrongful conviction statute, which provides monetary awards to qualifying persons. Prior to filing this petition in state court, he had also initiated a separate federal lawsuit under 42 U.S.C. § 1983, alleging violations of his constitutional rights stemming from the same prosecution and conviction.In the Criminal District Court for the Parish of Orleans, the State requested a stay of the wrongful conviction compensation proceedings, citing Louisiana Code of Civil Procedure article 532. This provision allows a court to stay proceedings when there is a related action in another jurisdiction involving the same parties and occurrence. The State argued that the federal suit should proceed first. The district court denied the motion to stay in open court on March 27, 2025. The State then sought supervisory review from the Louisiana Fourth Circuit Court of Appeal, which also denied relief on April 30, 2025.The Supreme Court of Louisiana reviewed the district court’s denial of the stay. The court examined the statutory differences between the state law compensation claim, which requires proof of factual innocence, and the federal civil rights action, which focuses on constitutional violations by individual actors. Concluding that the district court did not abuse its discretion in refusing to stay the state court proceedings—especially in light of the legislative instruction to decide wrongful conviction claims expeditiously—the Supreme Court of Louisiana affirmed the district court’s decision. The main holding is that denial of the State’s motion to stay the wrongful conviction compensation proceedings was proper under the circumstances. View "Williams v. State" on Justia Law

The case involves a plaintiff who sustained injuries after her vehicle was rear-ended by a vehicle owned and operated by the defendant, whose insurer was also named as a defendant. The plaintiff filed a petition for damages on December 22, 2020. The case proceeded to a jury trial, and on November 17, 2023, the jury found the defendant 100% at fault and awarded the plaintiff both special and general damages, totaling $736,871.62. The judgment, subsequently prepared and signed, awarded judicial interest “from November 17, 2023, the date of judicial demand, until paid.” However, November 17, 2023, was actually the date of the jury verdict, not the date of judicial demand.The defendants issued payment including judicial interest calculated only from the November 2023 verdict date. The plaintiff then moved to enforce the judgment, asserting that interest should accrue from the date of judicial demand—December 22, 2020. The Civil District Court for the Parish of Orleans granted this motion, finding the full amount of interest had not been paid. The Louisiana Court of Appeal, Fourth Circuit, affirmed, holding that judicial interest in tort cases accrues automatically from the date of judicial demand by operation of law, regardless of any drafting error in the judgment’s language.Upon certiorari, the Supreme Court of Louisiana held that the presence of the November 17, 2023 date in the judgment did not deprive the plaintiff of the statutory right to interest from the date of judicial demand. The Court concluded that enforcing the judgment to provide interest from the date the petition was filed did not constitute a substantive amendment and simply applied the mandatory provisions of Louisiana law. The rulings of both the district court and the appellate court were affirmed. View "Bilalis v. Drennan" on Justia Law

A driver, Ngoc Troung, was rear-ended by Marcus Sanders, whose vehicle was insured by Old American Indemnity Company. The impact rendered Troung’s vehicle inoperable, requiring repairs that included a new tire, exhaust system components, and other parts. The insurer initially paid for some repairs but later deducted $313.79 for “betterment”—a reduction based on the idea that new parts improved the vehicle beyond its pre-accident state. Troung had to pay this balance to retrieve his car and subsequently sued, arguing that Louisiana law does not allow for such deductions in third-party tort claims and seeking penalties for the insurer’s actions.The First Judicial District Court (trial court) held that betterment deductions were permissible because they were not expressly prohibited by Louisiana law or jurisprudence, and therefore did not consider Troung’s bad faith claims. On appeal, the Louisiana Court of Appeal, Second Circuit, reversed, finding that neither the law nor public policy allows a tortfeasor or insurer to reduce a not-at-fault party’s recovery for betterment in third-party tort claims. The appellate court also found the insurer acted in bad faith by imposing the betterment deduction and awarded statutory penalties.The Supreme Court of Louisiana reviewed the case on writ of certiorari. It affirmed the appellate court’s holding that Louisiana law does not permit a tortfeasor or their insurer to reduce a third-party tort victim’s property damage recovery by a betterment deduction. However, the Supreme Court reversed the award of penalties, concluding that the insurer’s conduct did not constitute a misrepresentation of pertinent facts and that penalties were not warranted because the legal issue was one of first impression. Thus, the Supreme Court affirmed in part and reversed in part. View "Troung v. Sanders" on Justia Law

A man was charged with three counts of possession of a firearm by a convicted felon after parole officers found three guns in the house where he was living with his family. Two days before the search, a parole officer had warned him that no guns could be present in the home after he said a gun was still in the house following a home invasion in which his son was shot. During the search, officers found one gun in a dresser drawer in the master bedroom, another under a mattress in the daughter’s bedroom, and a third in the cushions of the living room couch. Family members testified at trial that the guns belonged to them or their guests and that the defendant was unaware of their presence.A jury found the defendant guilty of attempted possession of a firearm by a convicted felon for the gun in the master bedroom and guilty of possession of a firearm by a convicted felon for the gun found in the living room couch. He was acquitted on the count related to the gun found in the daughter’s bedroom. The 26th Judicial District Court sentenced him to concurrent terms of imprisonment and fines. The Louisiana Court of Appeal, Second Circuit, affirmed the convictions and sentences, except for the fines, which it remanded for further consideration of the defendant’s ability to pay.The Supreme Court of Louisiana granted certiorari to review whether the evidence was sufficient to support the convictions. Applying the standard from Jackson v. Virginia, the court held that the evidence was insufficient to prove beyond a reasonable doubt that the defendant had the requisite intent to constructively possess either firearm. The court found no evidence that the defendant exercised dominion or control over the firearms or was aware of their presence. As a result, the Supreme Court of Louisiana reversed the defendant’s convictions and sentences. View "STATE OF LOUISIANA VS. WHITE" on Justia Law

A creditor obtained a judgment against an individual debtor and later sought to collect on that judgment by garnishing the debtor’s alleged employer, a company. The creditor, as successor in interest to the original plaintiff, filed a petition for garnishment against the company, asserting it employed or was otherwise indebted to the debtor. The company was served with the petition and interrogatories but did not timely file answers in court. However, before a hearing on the creditor’s motion for judgment pro confesso, the company provided sworn answers directly to the creditor, stating it never employed or owed anything to the debtor and identifying the debtor’s actual employer. The company did not file these answers into the court record. At the hearing, the court was not informed of the company’s responses and, based on the lack of record answers, rendered a judgment against the company for the full amount owed by the debtor.Subsequently, the company moved to reopen the garnishment proceedings and set aside the judgment, arguing it had provided the necessary information to the creditor before the hearing. The city court granted the motion and vacated its prior judgment, finding it had not been made aware of the company’s responses. On appeal, the Louisiana Court of Appeal, First Circuit, reversed and reinstated the original judgment against the company, holding that the relevant statute did not permit reopening a judgment pro confesso under these circumstances.The Supreme Court of Louisiana reviewed the case to determine whether La.R.S. 13:3923, as amended, allows a trial court discretion to reopen and reconsider a judgment pro confesso against a garnishee. The court held that, although the statute is clear and unambiguous, its application in this case would lead to absurd results because the trial court’s original judgment was based on an omission of material information. The Supreme Court reversed the court of appeal and reinstated the city court’s judgment vacating the original garnishment judgment, allowing the company an opportunity to prove it was not the debtor’s employer. View "FIRST PAY, INC. VS. DUKES" on Justia Law

A company acquired a tax title to certain immovable property in St. Martin Parish, Louisiana, after the original owners failed to pay property taxes. Following the expiration of the redemptive period, the company mailed post-tax sale notice to the executrix of the former owner’s succession at the address listed in the succession proceedings. The company then filed a petition to quiet title, and the executrix was personally served. In response, she filed a reconventional demand seeking to annul the tax sale, alleging she had not received adequate pre-tax and post-tax sale notice. The City, which had previously held a small interest in the property, was also named as a third-party defendant.The 16th Judicial District Court sustained exceptions of prescription raised by the company and the City, dismissing the executrix’s claims as untimely. On appeal, the Louisiana Third Circuit Court of Appeal reversed, finding the reconventional demand was timely because it was filed within six months of service of the petition to quiet title, as required by La. R.S. 47:2266. The appellate court also held that the failure to provide pre-tax sale notice could render the tax sale absolutely null, and that the company and the City bore the burden of proving the reconventional demand was prescribed.The Supreme Court of Louisiana reviewed the case and held that, following the 2008 revision to Louisiana’s tax sale statutes, failure to provide pre-tax sale notice for tax sales occurring after January 1, 2009, no longer results in an absolute nullity. Instead, such defects are relative nullities, subject to specific prescriptive periods under La. R.S. 47:2287. The Court further held that a nullity action brought as a reconventional demand in a quiet title action must also comply with the six-month limitation in La. R.S. 47:2266. The Court affirmed the appellate ruling regarding prescription but reversed on the issue of absolute nullity, remanding for further proceedings. View "BELAIRE DEVELOPMENT & CONSTRUCTION, LLC VS. SUCCESSION OF SHELTON" on Justia Law

Carlos Pellecer died after falling from a Werner brand aluminum extension ladder while working as a handyman in New Orleans. His family sued Werner Co., a Delaware corporation, and New Werner Holding Co., Inc., alleging that the ladder was unreasonably dangerous under the Louisiana Products Liability Act (LPLA) and that the defendants failed to warn about a 2018 recall. The ladder in question was manufactured in 1991 by Werner Co., a Pennsylvania corporation (later renamed Old Ladder), which filed for bankruptcy in 2006. The defendants had purchased certain assets, including the Werner name and trademark, from Old Ladder in 2007, but did not manufacture or sell the specific ladder model involved in the accident.The Civil District Court for the Parish of Orleans denied the defendants’ motion for summary judgment and, after a jury trial, entered judgment on a verdict finding the defendants to be manufacturers of the ladder under the LPLA. The jury awarded over $5 million in damages, apportioning fault equally between the defendants and Old Ladder. The defendants’ post-trial motions were denied. The Louisiana Court of Appeal, Fourth Circuit, affirmed the trial court’s judgment, holding that the jury could reasonably find the defendants to be manufacturers under the LPLA’s apparent manufacturer doctrine.The Supreme Court of Louisiana granted certiorari and held that the defendants were not manufacturers of the ladder under the LPLA. The court found no evidence that the defendants labeled the ladder as their own, held themselves out as its manufacturer, or exercised control over its design, construction, or quality. The court concluded that merely acquiring the Werner name and trademark did not make the defendants manufacturers of the subject ladder. The Supreme Court reversed the appellate court, vacated the trial court’s judgment, and rendered judgment in favor of the defendants. View "PELLECER VS. WERNER CO." on Justia Law

A railway employee, while working as a carman responsible for inspecting and repairing railcars, suffered injuries after the ballast beneath the tracks gave way, causing him to fall. He alleged that his employer failed to properly maintain the ballast under Tracks 46 and 47, despite prior complaints and a previous injury in the same area. The employer denied negligence and argued that federal regulations governing ballast, specifically 49 C.F.R. § 213.103 under the Federal Railroads Safety Act (FRSA), precluded the employee’s claim under the Federal Employer’s Liability Act (FELA).The District Court for the Parish of Caddo granted summary judgment for the employer, finding that the FRSA precluded the FELA claim. The Louisiana Court of Appeal, Second Circuit, affirmed, agreeing that federal regulation subsumed the field and thus barred the employee’s suit. The employee then sought review from the Supreme Court of Louisiana.The Supreme Court of Louisiana reviewed the case de novo and held that the FRSA does not preclude a FELA action. Relying on the reasoning in Pom Wonderful LLC v. Coca-Cola Co., the court found that the two federal statutes are complementary, not in irreconcilable conflict, and that Congress had not intended for the FRSA to preclude FELA claims. The court also determined that the employee presented sufficient evidence to create a genuine issue of material fact regarding negligence, making summary judgment inappropriate. Accordingly, the Supreme Court of Louisiana reversed the lower courts’ decisions and remanded the case for further proceedings. View "VAN BUREN VS. KANSAS CITY SOUTHERN RAILWAY COMPANY" on Justia Law

The plaintiff filed a civil action against two business entities, seeking relief in the Parish of Orleans. When initiating the lawsuit, the plaintiff requested service of citation on the defendants and paid all fees required by the clerk of court at the time of filing. Subsequently, the sheriff’s office sent an additional invoice for service fees, which the plaintiff paid after the ninety-day period prescribed by law for requesting service. The defendants argued that the plaintiff failed to properly request service within the statutory period because not all service-related fees were paid within ninety days.The Civil District Court for the Parish of Orleans denied the defendants’ exception of insufficiency of service of process and their motion for involuntary dismissal, finding that the plaintiff’s timely request for service, accompanied by payment of the initial fees, satisfied the statutory requirement. The defendants appealed, and the Louisiana Court of Appeal, Fourth Circuit, affirmed the district court’s decision, holding that Louisiana Code of Civil Procedure Article 1201(C) does not require payment of all service fees within the ninety-day period, only that service be requested.The Supreme Court of Louisiana granted certiorari to resolve conflicting appellate decisions on this issue. The court held that Article 1201(C) requires only that a plaintiff “request” service of citation within ninety days of filing the petition, and does not mandate that all service-related fees be paid within that period. The court reasoned that the statutory language is unambiguous and that payment requirements are addressed elsewhere in Louisiana law. Accordingly, the Supreme Court of Louisiana affirmed the judgment of the appellate court in favor of the plaintiff. View "DAROUSE VS. P.J.'S COFFEE OF NEW ORLEANS, LLC" on Justia Law