Justia Louisiana Supreme Court Opinion Summaries

In 1998, Jerry Lee Baldwin entered into a written agreement with the Board of Supervisors for the University of Louisiana System to serve as the head football coach at the University of Southwestern Louisiana, now University of Louisiana at Lafayette (UL). The contract provided that Baldwin’s employment with UL would last until January 31, 2003. By letter dated November 27, 2001, Baldwin was “relieved of [his] duties” as UL’s head coach effective November 26, 2001, after winning only six of twenty-seven games (an 18% win record). Baldwin continued to receive his full monthly salary and other employee benefits from UL including health insurance, accrual of leave time, and accrual of retirement credits for the remainder of the contract term. Baldwin sued the Board over the contract. Defendants sought review of the court of appeal’s determination that the coach’s contract had been terminated, which triggered a contractual obligation to provide notice. Interpreting the contract in its entirety, the Supreme Court found that the appellate court erred in finding that the failure of notice constituted a breach of contract under the facts of this case. Accordingly, the Court reversed the appellate court’s decision and reinstated the summary judgment rendered by the trial court, which dismissed the coach’s breach of contract claim against defendants. View "Baldwin v. Board of Supervisors for the University of Louisiana System" on Justia Law

Plaintiff Cynthia Holliday alleged she was unlawfully terminated from her employment with the State while on leave in 2009, in violation of the Family and Medical Leave Act of 1993's (FMLA) “self-care” provision. The State filed an Exception of No Cause of Action on the basis of sovereign immunity, which the district court denied. The Fourth Circuit denied Supervisory Writs. After its review, the Supreme Court found the trial court erred as matter of law in denying the State’s Exception of No Cause of Action. "While Louisiana may have waived sovereign immunity with respect to some claims, La. Const. art. 1 section 26 makes it clear the State has not waived its sovereignty within the federal system." The Louisiana Supreme Court found the trial court erred as a matter of law in determining the State had elected to waive its sovereign immunity for purposes of the FMLA. View "Holliday v. Board of Supervisors of LSU Agricultural & Mechanical College" on Justia Law

The question before the Supreme Court was whether La. R.S. 23:1203.1 applied to requests for medical treatment and/or disputes arising out of requests for medical treatment in cases in which the compensable accident or injury occurred prior to the effective date of the medical treatment schedule. The Office of Workers’ Compensation (OWC) ruled that the medical treatment schedule applied to all requests for medical treatment submitted after its effective date, regardless of the date of injury or accident. The court of appeal reversed, holding that La. R.S. 23:1203.1 was substantive in nature and could not be applied retroactively to rights acquired by a claimant whose work-related accident antedated the promulgation of the medical treatment schedule. The Supreme Court disagreed with the conclusion of the court of appeal and found that La. R.S. 23:1203.1 was a procedural statute and, thus, did not operate retroactively to divest a claimant of vested rights. As a result, the statute applied to all requests for medical treatment and/or all disputes emanating from requests for medical treatment after the effective date of the medical treatment schedule, regardless of the date of the work-related injury or accident. View "Church Mutual Insurance Co. v. Dardar" on Justia Law

The Supreme Court granted certiorari in this case to consider whether La. R.S. 23:1203.1 applied to a dispute arising out of a request for medical treatment where the request for treatment was submitted after the effective date of the statute and the medical treatment schedule, but the compensable accident and injury that necessitated the request occurred prior to that date. Both the Office of Workers’ Compensation (OWC) and the court of appeal ruled that La. R.S. 23:1203.1 applied to all requests for medical treatment submitted after the statute’s effective date, regardless of the date of accident and injury. Finding no reversible error, the Supreme Court affirmed. View "Cook v. Family Care Services, Inc." on Justia Law

In 2005, Patrick Richard sustained a work-related injury at the State Department of Transportation and Development ("DOTD"). After Mr. Richard's injury, DOTD began paying him workers' compensation benefits. Mr. Richard took disability retirement in 2007. Upon retiring, Mr. Richard spoke with a DOTD employee about the effect his receipt of workers' compensation benefits would have on his disability retirement benefits. Thereafter, Mr. Richard began simultaneously receiving disability retirement benefits through the Louisiana State Employees Retirement System ("LASERs"), and workers' compensation benefits through DOTD. In August 2007, DOTD informed Mr. Richard it had been overpaying him for workers' compensation benefits. In early 2011, DOTD filed a disputed claim for compensation, seeking an offset. In response, Mr. Richard filed an exception of prescription, arguing DOTD's claim for reimbursement was subject to a three-year prescriptive period. The matter proceeded to a trial before the Office of Workers' Compensation ("OWC"). The OWC denied Mr. Richard's exception of prescription. The OWC further held DOTD is entitled to an offset of $224.05 per week as of April 21, 2007, until Mr. Richard converted to regular retirement benefits at age 60. Mr. Richard appealed. The court of appeal affirmed in part and reversed in part. The court of appeal affirmed the OWC's denial of Mr. Richard's exception of prescription. However, the court found the OWC erred in holding DOTD was entitled to an offset of workers' compensation benefits. Upon review, the Supreme Court concluded the court of appeal incorrectly applied the law. Accordingly, the Court reinstated the OWC's judgment granting the employer an offset. View "Louisiana v. Richard" on Justia Law

A pharmaceutical distributor/repackager sought review of an appellate court decision that reversed a decision of the Louisiana Office of Workers' Compensation Administration. The Office awarded certain unpaid invoices for physician-dispensed medications (subject to a statutory limit) in favor of the distributor/repackager. The appellate court reversed based on a finding that the distributor/repackager did not have a right of action. After considering the applicable law, the Supreme Court found the anti-assignment language of La. R.S. 23:1205(A) did not prohibit the assignment of a health care provider's claims to a third party, an express contractual novation was effective, and an agent could statutorily be considered a health care provider based on the definition contained in La. R.S. 23:1021(6). Accordingly, the Court reversed the court of appeal's decision and remanded the case back to that court for further proceedings. View "Rebel Distributors Corp., Inc. v. Luba Workers' Comp." on Justia Law

Plaintiff Mary Soileau was injured while working for the Town of Mamou when a front-end loader detached from a tractor and struck her in the leg. She named the tractor manufacturer, the Town, Smith's Hardware (where the Town rented the tractor for employees' use), the hardware store's owners and their insurance company. Trial began with only the owners and their insurer as the remaining defendants in the suit. On the third day, Plaintiff moved to dismiss the owners and their company in the presence of the jury, stating that she did not seek any damages personally against them. Hearing no objections, the trial court granted the request, but made no written (and therefore signed) judgment of dismissal. On day four, the insurer moved for a directed verdict, based on contract language that it was obligated to pay only if its insureds were legally obligated to pay. The insurer's motion was denied, and ultimately over $9 million in damages were awarded to Plaintiff. Concluding that the trial court erred in denying the insurer's motion, the appellate court reversed, dismissing the insurance company. The issue before the Supreme Court centered on the effect Plaintiff's in-court dismissal of the insured parties was during her personal injury action. Upon review, the Supreme Court concluded that the appellate court erred in its analysis, reversed and remanded the case for further proceedings. View "Solieau v. Smith True Value & Rental" on Justia Law

The issue before the Supreme Court in this case centered on whether the minimum monthly salary referenced in La.R.S. 33:1992 included the supplemental amount paid by a municipality for purposes of calculating wage differentials for higher-ranking firefighters. current and former firefighters for the City of West Monroe filed suit against the City, alleging that the pay practices in use violated La.R.S. 33:1992. Particularly, Plaintiffs argued the base salary which was used to compute percentage differentials for higher ranking firefighters, failed to include the city supplemental pay of $300 per month. They contended the correct minimum monthly salary was $1,800, reflecting a $1,500 base salary in addition to a $300 supplemental salary. Without the supplement, the first year firefighters’ pay would not meet the minimum wage required by federal law. The City argued the proper minimum monthly salary was $1,500 because the city supplement was only a temporary monthly payment given to first-year firefighters. Upon review, the Supreme Court found that the interplay between La.R.S. 33:1992 and R.S. 33:2002 necessitated the exclusion of the enhanced amount of $300 from the base pay of a firefighter when calculating the pay differentials. Thus, the Court reversed the grant of partial summary judgment as to liability against the City of West Monroe and dismissed the plaintiffs’ suit in its entirety. View "West Monroe Firefighters Local 1385 v. City of West Monroe" on Justia Law

The Supreme Court granted the Louisiana Department of Transportation and Development's (DOTD) writ application to consider whether the Office of Workers' Compensation hearing officer erred in requiring a vocational rehabilitation counselor to comply with the so-called "Crain Brothers conditions," drafted by claimant's counsel, before the counselor could commence or continue to provide vocational rehabilitation services to the claimant. Upon review, the Court held that the hearing officer erred in imposing these conditions ostensibly as a prophylactic measure without an evidentiary showing that any of the imposed conditions were reasonably necessary to resolve or rectify a "dispute . . . concerning the work of the vocational counselor" as provided in La. Rev. Stat. 23:1226(B)(3)(a). Accordingly, the Court reversed the lower courts' rulings, and remanded the case to the Office of Workers' Compensation. View "Hargrave v. Louisiana" on Justia Law

The Supreme Court granted the writ of the City of Bossier City to determine the proper interpretation of La. R.S. 33:2501(C)(1); specifically, whether the statutory authority of the Bossier City Municipal Fire and Police Civil Service Board to modify discipline was conditioned upon a finding that the appointing authority acted in bad faith or without cause. After review, the Court found that a municipal fire and police civil service board has the statutory authority to review and modify the discipline imposed, even when the appointing authority acts in good faith for cause. View "City of Bossier City v. Vernon" on Justia Law