Alva Longino v. the City of Oakdale

Louisiana Court of Appeal·Decided November 3, 2021·No. CA-0021-0296·Unknown

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

CA 21-296

ALVA LONGINO

VERSUS

THE CITY OF OAKDALE, ET AL.

**********

APPEAL FROM THE THIRTY-THIRD JUDICIAL DISTRICT COURT PARISH OF ALLEN, NO. C-2018-513 HONORABLE JUDI F. ABRUSLEY, DISTRICT JUDGE

BILLY HOWARD EZELL JUDGE

Court composed of Elizabeth A. Pickett, Billy Howard Ezell, and D. Kent Savoie, Judges.

AFFIRMED. Bradley Charles Myers Kean Miller P. O. Box 3513 Baton Rouge, LA 70821-3513 (225) 387-0999 COUNSEL FOR DEFENDANT/APPELLEE: Risk Management, Inc.

Gregory W. Belfour Jones, Tete, Fonti & Belfour, L.L.P. 1135 Lakeshore Drive, 6th Floor P. O. Box 1930 Lake Charles, LA 70602 (337) 439-8315 COUNSEL FOR DEFENDANT/APPELLEE: Oakdale Housing Authority

Jonathan Clyde Vidrine P. O. Drawer 1019 Ville Platte, LA 70586 (337) 363-2772 COUNSEL FOR PLAINTIFF/APPELLANT: Alva Longino

Randall Brian Keiser Matthew L. Nowlin Keiser Law Firm, P.L.C. 5216 Rue Verdun P. O. Box 12358 Alexandria, LA 71315 (318) 443-6168 COUNSEL FOR DEFENDANT/APPELLEE: The City of Oakdale EZELL, Judge.

Alva Longino appeals the decision of the trial court below granting summary

judgment in favor of the City of Oakdale and the Housing Authority of the City of

Oakdale (hereinafter collectively referred to as Defendants). For the following

reasons, we hereby affirm the decision of the trial court.

Mr. Longino was a tenant in an apartment owned by the Housing Authority.

In front of his apartment was a sidewalk that had a drainpipe running underneath it,

which emptied into the building’s parking lot. On December 10, 2017, he stepped

off the sidewalk into the parking lot near the drainpipe, slipped, and fell, allegedly

injuring his back and hip. He then filed the current suit for damages against both

Defendants.

Defendants jointly filed a motion for summary judgment, claiming that the

sidewalk and drainpipe posed no unreasonable risk of harm and was open and

obvious. The trial court agreed and granted the motion for summary judgment.

From that decision, Mr. Longino appeals.

On appeal, Mr. Longino asserts three assignments of error. His first two

assignments of error both involve the motion for summary judgment. He argues

the trial court erred in granting the motion for summary judgment because issues of

material fact exist as to whether an unreasonably dangerous condition existed,

and/or whether the alleged defect was open and obvious. We will consider these

assignments of error as one.

Mr. Longino also asserts that the trial court erred in denying his motion for

new trial. While assigned as error, Mr. Longino did not brief any argument that

the trial court erred in failing to grant his motion for new trial. According to the

Uniform Rules-Louisiana Courts of Appeal, Rules 2-12.4(B)(4), issues not briefed on appeal are deemed abandoned. Because Mr. Longino failed to brief this

assignment of error, it is deemed abandoned and we will not address it.

Summary judgment procedure is favored and “is designed to secure the just,

speedy, and inexpensive determination of every action . . . . and shall be construed

to accomplish these ends.” La.Code Civ.P. art. 966(A)(2). In reviewing the trial

court’s decision on a motion for summary judgment, this court applies a de novo

standard of review. Jackson v. City of New Orleans, 12-2742, 12-2743 (La.

1/28/14), 144 So.3d 876, cert. denied, 574 U.S. 869, 135 S.Ct. 197 (2014).

The burden of proof is on the mover unless the mover will not bear the

burden of proof at trial, in which case the mover is not required to negate all

essential elements of the adverse party’s claim, but only to point out to the court

the absence of factual support for one or more of the elements necessary to the

adverse party’s claim. La.Code Civ.P. art. 966(D)(1). “The burden is on the

adverse party to produce factual support sufficient to establish the existence of a

genuine issue of material fact or that the mover is not entitled to judgment as a

matter of law.” Id.

“After an opportunity for adequate discovery, a motion for summary

judgment shall be granted if the motion, memorandum, and supporting documents

show that there is no genuine issue as to material fact and that the mover is entitled

to judgment as a matter of law.” La.Code Civ.P. art. 966(A)(3).

A fact is material if it potentially ensures or precludes recovery, affects a litigant’s ultimate success, or determines the outcome of the legal dispute. A genuine issue of material fact is one as to which reasonable persons could disagree; if reasonable persons could reach only one conclusion, there is no need for trial on that issue and summary judgment is appropriate.

Jackson, 144 So.3d at 882.

2 Mr. Longino cites Currie v. Scottsdale Indemnity Co., 12-1666 (La. App. 1

Cir. 8/26/13), 123 So.3d 742, for the proposition that the analysis of whether an

open and obvious defect presents an unreasonable risk of harm is not proper for

summary judgment, as he asserts that analysis is a determination of fact, taking

into consideration the victim’s own comparative fault, among other factors.

However, we point out that this 2013 decision has been overridden by the

Louisiana Supreme Court in its 2015 decision, Allen v. Lockwood, 14-1724 (La.

2/13/15), 156 So.3d 650. There, the supreme court clarified prior jurisprudence

and clearly stated that summary judgment should not be precluded when no legal

duty is owed because the condition encountered is open, obvious, and not

unreasonably dangerous. Further, the supreme court explained that:

Once a defendant points out a lack of factual support for an essential element in the plaintiff’s case, the burden then shifts to the plaintiff to come forward with evidence (by affidavit, deposition, discovery response, or other form sanctioned by La.Code Civ. P. arts. 966 and 967) to demonstrate that he or she would be able to meet his or her burden at trial.

Id. at 653.

The court concluded that “‘our jurisprudence does not preclude the granting

of a motion for summary judgment in cases where the plaintiff is unable to produce

factual support for his or her claim that a complained-of condition or things is

unreasonably dangerous.’” Id. at 653 (quoting Bufkin v. Felipe’s Louisiana, LLC,

14-288, p. 1 (La. 10/15/14), 171 So.3d 851, 859, (Guidry, J., concurring)).

Therefore, the jurisprudence is clear that:

[S]ummary judgment is appropriate where a defendant points out a lack of factual support for a plaintiff’s claim that a condition is unreasonably dangerous, and, upon the burden shifting to the plaintiff, the plaintiff is unable to produce factual support for his claim or to establish the existence of a genuine issue of material fact. LSA-C.C.P. art. 966(D). Thus, in the absence of any material issues of fact, a court

3 may determine by summary judgment that a defect is open and obvious and, therefore, does not present an unreasonable risk of harm. Temple [v. Morgan, 15-1159 (La.App. 1 Cir. 6/3/16)], 196 So.3d [71] at 78[, writ denied, 16-1255 (La. 10/28/16), 208 So.3d 889].

Minix v. Pilot Travel Ctrs., LLC, 18-1197, pp. 5-6 (La.App. 1 Cir. 5/31/19), 277

So.3d 810, 814, writ denied, 19-1074 (La. 10/8/19), 280 So.3d 149. See also

Green v. Calcasieu Par. Police Jury, 19-579 (La. App. 3 Cir. 2/27/20)

(unpublished opinion).

Here, Mr. Longino testified that he was aware of the drainpipe and the

alleged build-up of mud or muck for months prior to the accident. He stated that

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

Alva Longino v. the City of Oakdale, (La. Ct. App. 2021).

Alva Longino v. the City of Oakdale (Alva Longino v. the City of Oakdale) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Williams v. Leonard Chabert Medical Center
744 So. 2d 206 (Louisiana Court of Appeal, 1999)
Roy Bufkin, Jr. v. Felipe's Louisiana, LLC
171 So. 3d 851 (Supreme Court of Louisiana, 2014)
Currie v. Scottsdale Indemnity Co.
123 So. 3d 742 (Louisiana Court of Appeal, 2013)
Jackson v. City of New Orleans
144 So. 3d 876 (Supreme Court of Louisiana, 2014)
Allen v. Lockwood
156 So. 3d 650 (Supreme Court of Louisiana, 2015)
King v. Illinois Cent. R. R.
131 So. 68 (Louisiana Court of Appeal, 1930)