Barrynee Moore v. Sky Zone Franchise Group, LLC, Abc Corporation and Xyz Insurance Company

CourtLouisiana Court of Appeal
DecidedMarch 26, 2025
DocketCA-0024-0303
StatusUnknown

This text of Barrynee Moore v. Sky Zone Franchise Group, LLC, Abc Corporation and Xyz Insurance Company (Barrynee Moore v. Sky Zone Franchise Group, LLC, Abc Corporation and Xyz Insurance Company) 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
Barrynee Moore v. Sky Zone Franchise Group, LLC, Abc Corporation and Xyz Insurance Company, (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

24-303

BARRYNEE MOORE

VERSUS

SKY ZONE, ABC CORPORATION, AND XYZ INSURANCE COMPANY

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NUMBER C-20233611, DIVISION J HONORABLE KRISTIAN D. EARLES, DISTRICT JUDGE

SHARON DARVILLE WILSON JUDGE

Court composed of Jonathan W. Perry, Sharon Darville Wilson, and Clayton Davis, Judges.

AFFIRMED.

Davis, J., dissents and assigns written reasons. Lamont M. Hills David Daniels, II Luke Cartozzo HILLS DANIELS & ASSOCIATES, LLP 2439 Manhattan Boulevard, Suite 103 Harvey, Louisiana 70058 (504) 641-0016 COUNSEL FOR PLAINTIFF/APPELLANT: Barrynee Moore

Tom Easterly Cameron A. Murray TAYLOR, PORTER, BROOKS & PHILLIPS LLP 450 Laurel Street, 8th Floor Baton Rouge, Louisiana 70801 (225) 387-3221 COUNSEL FOR DEFENDANT/APPELLEE: Drastic Air Lafayette, LLC WILSON, Judge.

Plaintiff, Barrynee Moore (Moore), appeals a trial court judgment dismissing

her claims against Drastic Air Lafayette, LLC (Drastic Air) on the granting of its

exception of prescription. For the forgoing reasons, we affirm.

I.

ISSUES

Moore asserts the following issues for review:

1. Should a peremptory exception raising the objection of prescription be denied when a party is properly substituted and the substitution relates back to the timely filed petition for damages?

2. Should, alternatively, the doctrine of contra non valentem apply to suspend prescription where Drastic Air engaged in conduct that secreted its identity and which prevented Moore from availing herself of her judicial remedies?

II.

FACTS AND PROCEDURAL HISTORY

On July 9, 2022, Moore was a patron at a trampoline park located at 3814

Ambassador Caffery Parkway in Lafayette, Louisiana. She alleges that she was

injured when she jumped into a ball pit and hit the pit’s base, a solid surface of

cement. She alleges that the pit was unattended and lacked any instructions or

warnings.

On July 7, 2023, Moore filed suit against SKYZONE, ABC Corporation

(ABC), and XYZ Insurance Company (XYZ). She alleged that SKYZONE, which

the petition identifies as “a business corporation authorized to do and currently doing

business in the State of Louisiana[,]” was owned by ABC and insured by XYZ. The

original petition contains a paragraph alleging that “[s]aid defendants are indebted

unto your petitioner herein jointly, severally, and in Solido for all such damages as

are reasonable in the premises[.]” This allegation is realleged and affirmed in the

first supplemental and amending petition. On July 21, 2023, Moore filed a first supplemental and amending petition to

substitute Drastic Air Lafayette, LLC (Drastic Air), as a named defendant in place

of ABC. On September 11, 2023, in response to the amended petition, Drastic Air

filed an exception of prescription, alleging that Moore’s claims against it were

prescribed on the face of the pleading and that the applicable one-year prescriptive

period expired before any suit was filed that named a real and/or viable, non-

fictitious entity.

Before the exception was heard, Moore filed a second supplemental and

amending petition wherein she amended her original petition to name Sky Zone,

LLC (Sky Zone), a Nevada limited liability company authorized to do and doing

business in Louisiana, with a principal place of business at 86 N. University Avenue

in Provo, Utah, as a named defendant in each and every place that SKYZONE was

previously mentioned. The second supplemental and amending petition added the

following defendants: (1) Sky Zone Franchise Group, LLC (Sky Zone Franchise

Group); (2) Circustrix Holdings, LLC (Circustrix); (3) Fun Spot Manufacturing,

LLC (Fun Spot); (4) ABEO North America, Inc. (ABEO); (5) Trampoline

Acquisition Parent Holdings, LLC (Trampoline Acquisition); (6) Palladium Equity

Partners, LLC (Palladium Equity); (7) Palladium Equity Partners IV, LLC

(Palladium Equity IV); and (8) Palladium Capital Management IV, LLC (Palladium

Capital IV). This petition alleged that Sky Zone, Drastic Air, and the eight additional

defendants “designed, manufactured, assembled, constructed, franchised, owned,

controlled, maintained, operated, managed, trained, supervised, marketed, and

solicited business” for the trampoline park where she was injured “by advertising its

attractions, activities and events through out [sic] the State of Louisiana and

elsewhere.” The petition further alleged that Drastic Air is the franchisee of Sky

Zone and/or Sky Zone Franchise Group and/or Circustrix and/or Trampoline 2 Acquisition and/or Palladium Equity and/or Palladium Equity IV and/or Palladium

Capital IV. It further alleged that Sky Zone and/or Skyzone Franchise Group and/or

Fun Spot “invented, created, produced, designed, manufactured, assembled,

constructed, marketed, sold, franchised, and/or controlled by contract over two

hundred (200) recreation facilities known as Sky Zone Indoor Trampoline Parks,”

including the Lafayette location where Moore was injured.

The second supplemental and amending petition also alleged that Drastic Air

referred to and intentionally misrepresented itself as Sky Zone throughout all

correspondence and communications concerning Moore’s accident. Various email

correspondence and printouts from the Louisiana Secretary of State’s website were

attached to this petition.

The exception of prescription was heard on February 20, 2024. At the hearing,

Drastic Air called Chris Fudge, a member of Drastic Air and its registered agent, and

his wife, Kimberly Fudge, also a member of Drastic Air, to testify. Drastic Air also

introduced the following evidence: (1) a printout from the Louisiana Secretary of

State’s website showing the results of a search for “Drastic Air Lafayette, LLC;” (2)

citation to Sky Zone with Moore’s original petition attached; (3) citation to Drastic

Air with Moore’s original petition and first supplemental and amending petition

attached; (4) a printout from the Louisiana Secretary of State’s website showing the

results of a search for “Sky Zone;” and (5) Moore’s first supplemental and amending

petition. The only evidence introduced by Moore was a printout from Sky Zone’s

website with the results of Google search of the 3814 Ambassador Caffery Parkway

address attached. The second supplemental and amending petition for damages was

not introduced into evidence. The second supplemental and amending petition and

the email correspondence were attached to Moore’s memorandum in opposition to

the exception of prescription. 3 The trial court granted the exception of prescription in open court. A written

judgment was prepared by Drastic Air’s counsel and signed by the trial court on

February 28, 2024. The judgment granted the exception in favor of Drastic Air and

dismissed Moore’s claims against Drastic Air with prejudice. This timely devolutive

appeal followed.

III.

STANDARD OF REVIEW

In Smith v. Acadian Ambulance Serv., Inc., 22-626, p. 3 (La.App. 3 Cir.

3/22/23), 363 So.3d 564, 567, we noted:

Ordinarily, a judgment granting an exception of prescription is reviewed de novo because it raises a legal question, but when evidence is introduced at the hearing, the trial court’s findings of fact are subject to the manifest error standard of review. Jenkins v. Kauffman, 21-1596 (La.App. 1 Cir.

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Barrynee Moore v. Sky Zone Franchise Group, LLC, Abc Corporation and Xyz Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barrynee-moore-v-sky-zone-franchise-group-llc-abc-corporation-and-xyz-lactapp-2025.