Alois Reiners v. St. Landry Hospital Service District

CourtLouisiana Court of Appeal
DecidedMay 30, 2007
DocketCA-0007-0158
StatusUnknown

This text of Alois Reiners v. St. Landry Hospital Service District (Alois Reiners v. St. Landry Hospital Service District) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alois Reiners v. St. Landry Hospital Service District, (La. Ct. App. 2007).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

07-158

ALOIS REINERS, ET AL.

VERSUS

ST. LANDRY HOSPITAL SERVICE DISTRICT TWO d/b/a OPELOUSAS GENERAL HOSPITAL, ET AL.

**********

APPEAL FROM THE TWENTY-SEVENTH JUDICIAL DISTRICT COURT, PARISH OF ST. LANDRY, NO. 97-C-3439-C HONORABLE ALONZO HARRIS, DISTRICT JUDGE

J. DAVID PAINTER JUDGE

Court composed of Michael G. Sullivan, Billy H. Ezell, and J. David Painter, Judges.

AFFIRMED.

Nicholas Gachassin, Jr. Julie Savoy Gachassin Law Firm, L.L.C. P.O. Box 80369 Lafayette, LA 70508-0369 Counsel for Defendants-Appellants: St. Landry Hospital Service District Two d/b/a Opelousas General Hospital, et al. Thomas R. Shelton Shelton Law Firm 1326 West Pinhook Road, Suite 200 P.O. Drawer 52548 Lafayette, LA 70505-2548 Counsel for Plaintiffs-Appellees: Alois Reiners, et al. PAINTER, Judge.

Medical malpractice Plaintiffs, Alois Reiners, Lucille G. Reiners, Wayne A.

Reiners, Mark A. Reiners, Karl A. Reiners, Rebecca Reiners Savoie, and Carolyn

Reiners Bubrig, filed a petition to enforce settlement agreement and for penalties

pursuant to La.R.S. 22:1220. The trial court granted the motion, found Defendants

in bad faith, and awarded penalties in the total amount of $35,000.00 (or $5,000.00

to each Plaintiff). Defendants, St. Landry Hospital Service District Two d/b/a

Opelousas General Hospital, Wendy DeVillier, R.N., and A. Biba, R.N., appeal this

ruling. For the following reasons, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

This lawsuit originated as an action in medical malpractice filed by Plaintiffs

with respect to the treatment received by Alois Reiners at Opelousas General Hospital

on or about April 15, 1995 and thereafter. Trial by jury was scheduled to begin April

21, 2003. However, on April 1, 2003, Defendants extended a written settlement offer

to Plaintiffs, which specified that Medicare would be a named payee on the settlement

check and that Defendants would be provided with payee information including the

names of all Plaintiffs and the attorney’s tax identification number. Plaintiffs

responded, that same date, and accepted the offer of settlement. Additionally,

Plaintiffs informed Defendants that they would be seeking excess damages from the

Patients’ Compensation Fund (the PCF), that Plaintiffs’ attorney would determine the

amount due Medicare through negotiations with Medicare, and that the firm’s tax

identification number and Plaintiffs’ social security numbers would be provided

forthwith. The trial court was notified of the settlement.

Defendants contend that seven weeks lapsed with no information from

Plaintiffs. On May 20, 2003, counsel for Defendants sent a letter to Plaintiffs’

1 counsel requesting information on the status of the discussions with Medicare.

Defendants contend that they received no response to this correspondence.

Defendants’ counsel sent another letter to counsel for Plaintiffs on August 22, 2003,

enclosing draft settlement documents. Defendants contend that several additional

months lapsed with no response from counsel for Plaintiffs, and, so, on March 24,

2004, counsel for Defendants contacted Medicare and learned that no request had

been made by Plaintiffs or their counsel to determine the lien. This information was

communicated to Plaintiffs’ counsel, who in turn contacted Medicare on March 29,

2004, to request a determination of the lien amount. Defendants contend that they

waited another year for some response and, receiving none, attempted to coordinate

efforts with the PCF for a joint settlement. Defendants claim that they again had no

response from Plaintiffs’ counsel. Defendants contend that another year went by with

no activity relative to the settlement, and then, on March 22, 2006, counsel for

Defendants was contacted by counsel for the PCF, who related that there was no

Medicare lien and that Plaintiffs had rejected the PCF’s settlement offer. On April

28, 2006, draft settlement documents were again forwarded to Plaintiffs’ counsel.

Defendants contend that a month elapsed before any communication from Plaintiffs’

counsel was forthcoming. Defendants contend that they still had not been provided

with payee information.

Plaintiffs assert that by letter dated April 1, 2003, their counsel informed

counsel for Defendants that designating Medicare as a payee on the settlement check

would be unacceptable, since they anticipated a dispute as to which medical services

rendered would be included in the lien. Plaintiffs further assert that Defendants

accepted this counter-offer by stating that they were “prepared to make payments in

this matter upon resolution of the Medicare lien by your office” in correspondence

2 dated May 20, 2003. Furthermore, Plaintiffs contend that once Defendants were

advised that there was no Medicare lien, there was nothing to prevent Defendants

from issuing the settlement check. Plaintiffs point out that 1,178 days (or three years

and two months) elapsed between the time of the settlement agreement and the date

Plaintiffs filed the petition to enforce the settlement.

On June 26, 2006, Plaintiffs filed a petition to enforce the settlement and

sought penalties under La.R.S. 22:1220. The trial court granted the motion and

awarded penalties in the total amount of $35,000.00, or $5,000.00 per Plaintiff.

Defendants’ motion for new trial was denied, and this appeal followed. We find no

manifest error in the trial court’s finding of bad faith, and, because Defendants have

not specifically appealed the amount of penalties awarded, we affirm the judgment

awarding a total of $35,000.00 in penalties to Plaintiffs.

DISCUSSION

Louisiana Revised Statutes 22:1220 provides, in pertinent part, as follows:

A. An insurer, including but not limited to a foreign line and surplus line insurer, owes to his insured a duty of good faith and fair dealing. The insurer has an affirmative duty to adjust claims fairly and promptly and to make a reasonable effort to settle claims with the insured or the claimant, or both. Any insurer who breaches these duties shall be liable for any damages sustained as a result of the breach.

B. Any one of the following acts, if knowingly committed or performed by an insurer, constitutes a breach of the insurer's duties imposed in Subsection A:

....

(2) Failing to pay a settlement within thirty days after an agreement is reduced to writing.

C. In addition to any general or special damages to which a claimant is entitled for breach of the imposed duty, the claimant may be awarded penalties assessed against the insurer in an amount not to exceed two times the damages sustained or five thousand dollars,

3 whichever is greater. Such penalties, if awarded, shall not be used by the insurer in computing either past or prospective loss experience for the purpose of setting rates or making rate filings.

The determination of arbitrary and capricious behavior, or bad faith, in failing

to timely pay a settlement is a factual determination which is subject to the manifest

error standard of review. Aguillard v. Crowley Garment Mfg. Co., 01-594 (La.App.

3 Cir. 2/27/02), 824 So.2d 347, writs denied, 02-1348 (La. 8/30/02), 823 So.2d 955,

02-1170 (La. 8/30/02), 823 So.2d 956. Furthermore, proof of actual damages is not

a prerequisite to the recovery of penalties under La.R.S. 22:1220, and the trial court’s

grant of penalties is discretionary.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Rogers v. Commercial Union Ins. Co.
796 So. 2d 862 (Louisiana Court of Appeal, 2001)
Aguillard v. Crowley Garment Mfg. Co.
824 So. 2d 347 (Louisiana Court of Appeal, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
Alois Reiners v. St. Landry Hospital Service District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alois-reiners-v-st-landry-hospital-service-district-lactapp-2007.