Justia Louisiana Supreme Court Opinion Summaries

The petitioner, Rafael Antonio Mena Chavez, filed a lawsuit under the false name "Sergio Balboa" after sustaining injuries while working for Southern Recycling, LLC. Chavez used the alias to obtain employment and continued using it when seeking medical attention and workers' compensation benefits. He later filed a lawsuit against Metso Minerals Industries, Inc., alleging product liability and negligence. Southern Recycling and other intervenors joined the suit, claiming they had paid substantial workers' compensation benefits to "Sergio Balboa."The Orleans Civil District Court denied Metso's motion to dismiss the case, despite Metso's argument that Chavez's use of a false identity undermined the judicial process. The court found no fraud or willful deception at that stage and allowed the case to proceed. Metso's subsequent writ to the Louisiana Court of Appeal, Fourth Circuit, was also denied. Metso then sought relief from the Louisiana Supreme Court.The Louisiana Supreme Court reversed the lower courts' decisions, holding that courts have inherent authority to dismiss an action with prejudice when a petitioner’s conduct undermines the integrity of the judicial process. The court found that Chavez's prolonged use of a false identity was a calculated deception that harmed the judicial system and the defendants. The court dismissed Chavez's petition with prejudice and remanded the case to the trial court to determine whether the intervenors' petition survives the dismissal of Chavez's petition. View "CHAVEZ VS. METSO MINERALS INDUSTRIES, INC." on Justia Law

The case involves the Police Jury of Calcasieu Parish, a political subdivision of Louisiana, which suffered property damage from Hurricanes Laura and Delta in 2020. The Police Jury had insurance policies with a syndicate of eight domestic insurers. The insurers sought to compel arbitration in New York under New York law for the approximately 300 property damage claims. The Police Jury alleged underpayment and untimely payments by the insurers and filed suit in state court, which was later removed to the United States District Court for the Western District of Louisiana.The Western District Court granted the Police Jury's motion to certify three questions of Louisiana law to the Louisiana Supreme Court. The questions concerned the validity of arbitration clauses in insurance policies issued to Louisiana political subdivisions, particularly in light of a 2020 amendment to La. R.S. 22:868 and the applicability of La. R.S. 9:2778, which bars arbitration clauses in contracts with the state or its political subdivisions.The Louisiana Supreme Court addressed the certified questions. First, it held that the 2020 amendment to La. R.S. 22:868, which allowed forum or venue selection clauses in certain insurance contracts, did not implicitly repeal the prohibition of arbitration clauses in all insurance contracts under La. R.S. 22:868(A). Second, the court determined that La. R.S. 9:2778 applies to all contracts with political subdivisions, including insurance contracts, thereby prohibiting arbitration outside Louisiana or the application of foreign law. Third, the court held that a domestic insurer cannot use equitable estoppel to enforce an arbitration clause in another insurer’s policy against a political subdivision, as it would contravene the positive law prohibiting arbitration clauses in La. R.S. 22:868(A)(2).The Louisiana Supreme Court answered all three certified questions, maintaining the prohibition of arbitration clauses in insurance policies issued to Louisiana political subdivisions and affirming the applicability of La. R.S. 9:2778 to such contracts. View "POLICE JURY OF CALCASIEU PARISH VS. INDIAN HARBOR INSURANCE CO." on Justia Law

In 2019, Huberto Martinez's vehicle slid off an icy highway in Shreveport, Louisiana, and was subsequently struck by a tractor-trailer driven by Salah Dahir and owned by Starr Carriers, LLC. Martinez and his passengers, Ada Licona, Rosa Rivera, and Salvador Flores, filed lawsuits against Dahir, Starr Carriers, and their insurer, American Transportation Group Risk Retention Group, Inc. (ATG), which had a policy limit of $1,000,000. Martinez settled his claims before trial, but the jury awarded substantial damages to the remaining plaintiffs, exceeding ATG's policy limit.The First Judicial District Court, Parish of Caddo, denied the defendants' post-trial motions and rendered a final judgment in favor of the plaintiffs for $2,802,054.66 plus interest and costs. The defendants sought a suspensive appeal and requested a bond less than the entire judgment, citing their inability to secure such a bond. The trial court set the bond at the full judgment amount. ATG posted a bond for its remaining policy limits plus interest and costs. The Second Circuit Court of Appeal denied ATG's request for supervisory review.The Supreme Court of Louisiana reviewed the case and held that an insurer is not required to post a bond exceeding its policy limits to secure a suspensive appeal. The court determined that requiring ATG to post a bond for the entire judgment would impair the contractual limits of liability and violate the contract clause of the state constitution. The court allowed ATG to post a bond up to its policy limits for a suspensive appeal and to devolutively appeal the remainder of the judgment. The case was remanded for further proceedings consistent with this holding. View "MARTINEZ VS. AMERICAN TRANSPORT GROUP RISK RETENTION GROUP, INC." on Justia Law

The case involves an automobile accident that occurred on June 2, 2018, where Theresa Fisher's vehicle was rear-ended by a vehicle driven by Steven Harter, Jr., causing a chain reaction. Steven Harter, Sr., was also named as a defendant because his son was a minor at the time. The plaintiff sought a declaratory judgment challenging the constitutionality of La. R.S. 13:4163, which allows legislators and legislative employees to obtain continuances or extensions of court dates.The 1st Judicial District Court upheld the constitutionality of La. R.S. 13:4163, and the appellate court declined the plaintiff’s application for supervisory review. The district court had previously granted a partial summary judgment in favor of the plaintiff, finding Steven Harter, Jr. negligent and his father vicariously liable. The court also dismissed the defendants' affirmative defenses of comparative and third-party fault. However, the district court denied the plaintiff's motion for declaratory judgment on the constitutionality of La. R.S. 13:4163, stating that the statute did not violate the separation of powers or any constitutional rights.The Supreme Court of Louisiana reviewed the case and reversed the district court's decision. The court held that La. R.S. 13:4163 is unconstitutional on its face because it usurps the judiciary's power to grant or deny continuances, violating the separation of powers doctrine. The court emphasized that the statute mandates courts to grant continuances ex parte, without a hearing, which undermines the courts' inherent authority to manage their dockets and ensure the fair administration of justice. The case was remanded to the district court with instructions to conduct a contradictory hearing for all contested motions for continuance. View "FISHER VS. HARTER" on Justia Law

Bonny Babin Maloney passed away in May 2020, leaving behind a will that included a no-contest clause. Her husband, Robert Maloney, Sr., had predeceased her in June 2019, and his will also contained a no-contest clause. Upon Robert Sr.'s death, Mrs. Maloney inherited various assets, including the family home. Mrs. Maloney's will bequeathed the family home to her daughter Julie and included a clause disinheriting any heir who contested the will or engaged in a controversy against the executor concerning her estate.Robert Jr. and Kurt, two of Mrs. Maloney's children, filed a petition in Robert Sr.'s succession to annul the codicils of his will, claiming lack of testamentary capacity. They obtained a temporary restraining order (TRO) to prevent Craig, the executor of both estates, from administering the assets, including the family home. The trial court ruled that Robert Sr. had testamentary capacity and disinherited Robert Jr. and Kurt under the no-contest clause in Robert Sr.'s will. Craig then sought to enforce the no-contest clause in Mrs. Maloney's will, arguing that the TRO violated the clause.The Supreme Court of Louisiana reviewed the case to determine if the no-contest clause in Mrs. Maloney's will was enforceable. The court held that the clause was clear and unambiguous, and Robert Jr. and Kurt's actions in obtaining the TRO against Craig, in his capacity as executor of Mrs. Maloney's estate, triggered the clause. Consequently, Robert Jr. and Kurt were disinherited from Mrs. Maloney's estate. The court affirmed the lower court's grant of partial summary judgment in favor of Craig, upholding the enforcement of the no-contest clause. View "SUCCESSION OF MALONEY" on Justia Law

Advanced Benefit Concepts, Inc. (ABC) filed a breach of contract lawsuit against Access Health, Inc., Preferred Care Services, Inc., and Blue Cross and Blue Shield of Alabama (collectively, Access Health). ABC alleged that Access Health failed to pay fees owed under an agreement where ABC helped Access Health secure a contract with the State of Louisiana’s Office of Group Benefits (OGB). Access Health countered that the contract was null and void because ABC did not register as a lobbyist as required by the Louisiana Executive Branch Lobbying Act.The district court ruled in favor of Access Health, declaring the contract void due to ABC’s failure to register as a lobbyist. The court granted Access Health’s motion for summary judgment, dismissing ABC’s breach of contract claim. ABC’s exceptions of lack of subject matter jurisdiction and prescription were overruled. ABC appealed the decision.The Louisiana Court of Appeal, First Circuit, reversed the district court’s decision, holding that the Board of Ethics had exclusive jurisdiction to determine the validity of the contract under the Lobbying Act. The appellate court concluded that the district court lacked subject matter jurisdiction to declare the contract void and reversed the summary judgment.The Supreme Court of Louisiana reviewed the case and reversed the appellate court’s decision. The Supreme Court held that the district court has subject matter jurisdiction to hear the contractual dispute, including the affirmative defense of nullity based on the Lobbying Act. The court emphasized that the Executive Branch Lobbying Act does not deprive the district court of jurisdiction and that the district court can consider whether the contract is an absolute nullity under Louisiana Civil Code article 2030. The case was remanded to the appellate court to consider the exception of prescription and the merits of the summary judgment motion. View "ADVANCED BENEFIT CONCEPTS, INC. VS. BLUE CROSS AND BLUE SHIELD OF ALABAMA" on Justia Law

In July 2024, Judge Marcus L. Hunter filed a notice of candidacy for the office of Associate Justice of the Louisiana Supreme Court, certifying that he had filed his federal and state income tax returns for the previous five years. Elisa Knowles Collins, a resident of District Two, challenged his candidacy, alleging that Judge Hunter falsely certified his tax filings. At trial, Collins presented an affidavit from the Louisiana Department of Revenue indicating no confirmed tax filings for Hunter for 2021, 2022, and 2023. Hunter's accountant testified that she electronically filed his 2022 and 2023 tax returns, but they were rejected by the IRS.The 19th Judicial District Court overruled Collins' challenge, finding that although she established a prima facie case, Hunter provided sufficient evidence to counter it. The Court of Appeal, Fourth Circuit, affirmed this decision, with two judges dissenting, arguing that Hunter did not meet his burden of proof.The Supreme Court of Louisiana reviewed the case and found that Hunter failed to provide sufficient evidence to rebut Collins' prima facie case. The court noted that Hunter did not testify or provide copies of his tax returns, and his accountant's testimony and documents were insufficient to prove that the tax returns were filed. Consequently, the Supreme Court reversed the lower courts' judgments, declared Hunter ineligible as a candidate, and directed the Secretary of State to remove his name from the ballot or void any votes cast for him if the ballot had already been printed. View "COLLINS VS. CHAMBERS" on Justia Law

The case involves James and Wilma Self, who filed a lawsuit as representatives of a class of plaintiffs who own unleased mineral interests in Louisiana within compulsory drilling units operated by BPX Operating Company. The plaintiffs alleged that BPX's practice of withholding post-production costs from their pro rata share of production was improper. BPX sought dismissal of the claim, arguing that the Louisiana doctrine of negotiorum gestio provides a mechanism for unit operators to be reimbursed for post-production costs not otherwise covered by specific statutes. The federal district court granted BPX's motion to dismiss.On appeal, the United States Fifth Circuit found the law unsettled on this issue and certified a question of law to the Supreme Court of Louisiana. The question was whether the doctrine of negotiorum gestio applies to unit operators selling product in accordance with La. R.S. 30:10(A)(3).The Supreme Court of Louisiana found that the doctrine of negotiorum gestio does not apply and cannot be a basis for liability as a unit operator is always acting "with authority." The court reasoned that the oil and gas conservation law provides a unique quasi-contractual relationship between unleased mineral owners and unit operators, which cannot be applied consistently with the doctrine of negotiorum gestio. The court further explained that a party is only a gestor if his action is taken "without authority," but a unit operator is statutorily authorized by La. R.S. 30:10(A)(3) to sell an unleased owner's share of production when the unleased owner has not arranged to dispose of his share. Therefore, a unit operator who sells an owner's production under the statutory authority of La. R.S. 30:10(A)(3) cannot be a gestor under La. C.C. art. 2292. The court answered the certified question and sent its judgment to the United States Court of Appeals for the Fifth Circuit and to the parties. View "SELF VS. BPX OPERATING COMPANY" on Justia Law

This case involves a vehicular collision that occurred in a construction zone on Interstate 10 in LaPlace, Louisiana. The plaintiff, Frank Cushenberry, was driving a commercial vehicle when he collided with a truck owned by Barber Brothers Contracting Company, LLC. The truck was partially in the right lane of the highway while backing up to move traffic cones. The collision resulted in significant injuries to Mr. Cushenberry, including a traumatic brain injury.The case was initially heard in a lower court, where the jury found Barber Brothers 100% at fault for the accident and awarded substantial damages to Mr. Cushenberry, his wife, and their two minor children. Barber Brothers appealed the decision, arguing that the trial court erred in its jury instructions and that the jury erred in finding Barber Brothers solely at fault.The Supreme Court of Louisiana found that the trial court did err in its jury instructions, but that this error was not reversible. The court also found that the jury erred in finding Barber Brothers solely at fault for the accident. The court determined that Barber Brothers was 80% at fault and Mr. Cushenberry was 20% at fault.The court also found that the jury abused its discretion in awarding general damages of $10,750,000.00 to Mr. Cushenberry, and loss of consortium damages of $2,500,000.00 to his spouse, Robin Cushenberry, and $1,500,000.00 to each of their minor children. The court reduced these awards to $5,000,000.00 in general damages to Mr. Cushenberry, and loss of consortium damages of $400,000.00 to Mrs. Cushenberry and $100,000.00 to each child.As amended, the trial court judgment was affirmed. View "BARBER BROTHERS CONTRACTING COMPANY, LLC VS. CAPITOL CITY PRODUCE COMPANY, LLC" on Justia Law

The case involves Angela Pickard and others who sued Amazon.com, Inc. after a battery charger purchased from Amazon's online marketplace malfunctioned, causing a fire that resulted in the death of Archie Pickard. The charger was sold by a third-party seller, Jisell, not Amazon. However, Jisell used Amazon's optional service, "Fulfillment by Amazon," which meant that the product was stored in an Amazon warehouse and delivered by Amazon. The plaintiffs claimed that Amazon was liable under the Louisiana Products Liability Act and for negligent undertaking.The case was initially heard in the Western District Court of Louisiana. Amazon filed a motion for summary judgment, and in response, the court certified two questions to the Supreme Court of Louisiana: whether Amazon was a "seller" under Louisiana products-liability law, and under what circumstances Amazon could be liable for injuries sustained by the purchaser of a defective product based on a theory of negligent undertaking.The Supreme Court of Louisiana held that under the Louisiana Products Liability Act, the operator of an online marketplace is a "seller" of third-party products sold in its marketplace when the operator did not hold title to the product but had physical custody of the product in its distribution warehouse and controlled the process of the transaction and delivery. The court also held that an operator may be liable for injuries if, subject to standards established by the court’s precedent, the operator assumed a duty to identify and remove unreasonably dangerous products from its marketplace. The court applied Section 324A of the Restatement of Torts Second to determine if an operator of an online marketplace assumed a duty owed by a third-party seller and is liable for any damages caused by the breach of that duty. View "ANGELA PICKARD VS. AMAZON.COM, INC." on Justia Law