Bradley Broussard v. Gulfport Energy Corporation

CourtLouisiana Court of Appeal
DecidedJune 5, 2019
DocketCA-0018-0838
StatusUnknown

This text of Bradley Broussard v. Gulfport Energy Corporation (Bradley Broussard v. Gulfport Energy Corporation) 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
Bradley Broussard v. Gulfport Energy Corporation, (La. Ct. App. 2019).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

18-838

BRADLEY BROUSSARD

VERSUS

GULFPORT ENERGY CORPORATION, ET AL.

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. 2015-2233 HONORABLE PATRICK L. MICHOT, DISTRICT JUDGE

PHYLLIS M. KEATY JUDGE

Court composed of Sylvia R. Cooks, Billy Howard Ezell, and Phyllis M. Keaty, Judges.

REVERSED.

Randall Kurt Theunissen S. Brian Perry Allen & Gooch Post Office Box 81129 Lafayette, Louisiana 70598-1129 (337) 291-1000 Counsel for Defendants/Appellees: Wet Tech Lighting, Inc. Wet Tech Energy, Inc. Robert A. Mahtook, Jr. Mahtook & LaFleur, LLC Post Office Box 3089 Lafayette, Louisiana 70502-3089 (337) 266-2189 Counsel for Defendant/Appellee: AFX Petrologix, LLC

Leo Raymond McAloon, III Gieger, LaBorde & Laperouse, LLC One Shell Square 701 Poydras Street, Suite 4800 New Orleans, Louisiana 70139 (504) 561-0400 Counsel for Defendant/Appellee: Shamrock Management, LLC

Marc D. Moroux Juneau David, APLC Post Office Drawer 51268 Lafayette, Louisiana 70505-1268 (337) 261-1408 Counsel for Defendant/Appellee: Gulfport Energy Corporation

Thomas M. Flanagan Sean Brady Andy Dupre Anders F. Holmgren Flanagan Partners LLP 201 St. Charles Avenue, Suite 2405 New Orleans, Louisiana 70170 (504) 569-0235 Counsel for Plaintiff/Appellant: Bradley Broussard

J. Kyle Findley Kala Sellers Adam Lewis Arnold & Itkin, LLP 6009 Memorial Drive Houston, Texas 77007 (713) 222-3800 Counsel for Plaintiff/Appellant: Bradley Broussard

F. Douglas Ortego LeBas Law Offices 201 Rue Iberville, Suite 100 Lafayette, Louisiana 70508 (337) 236-5500 Counsel for Intervenor: American Interstate Insurance Company KEATY, Judge.

Plaintiff/Appellant, Bradley Broussard, appeals the trial court’s grant of

summary judgment in favor of Defendant/Appellee, Wet Tech Lighting, Inc. For

the following reasons, the trial court’s judgment is reversed.

FACTS AND PROCEDURAL HISTORY

This personal injury matter stems from injuries sustained by Broussard on

January 21, 2015, while working in the course and scope of his employment with

AFS Petrologix, LLC, on platform 114 in the East Hackberry Field in Calcasieu

Lake, State Lease 50. Broussard was inspecting a navigational light on top of a pole

when it broke, causing him to fall into the water below and sustain injuries. As a

result, Broussard filed an Original Petition for Damages on May 6, 2015, against

Gulfport Energy Corporation as the owner and/or operator of the platform based

upon negligence and premises liability. Broussard’s workers’ compensation insurer,

American Interstate Insurance Company, filed a Petition of Intervention. On

April 26, 2016, Broussard filed his First Amended Petition for Damages, naming

Wet Tech Lighting, Inc., Wet Tech Energy, Inc., and Shamrock Management, L.L.C.,

as additional Defendants. In his amended petition, Broussard alleged that Wet Tech

Lighting, Wet Tech Energy, and Shamrock were negligent by failing to properly

inspect and maintain the navigational light and pole.

On April 11, 2018, Wet Tech Lighting filed a motion for summary judgment,

alleging that it owed no duty to Broussard because the contract governing the work

at issue was executed between Gulfport and Wet Tech Energy, a separate and

different entity from Wet Tech Lighting. Broussard filed an opposition

memorandum and, alternatively, a motion to continue the summary judgment

hearing. Following a hearing on May 14, 2018, the trial court denied Broussard’s

motion to continue and granted Wet Tech Lighting’s motion for summary judgment. The trial court’s written judgment was signed on May 24, 2018, which Broussard

now appeals.

On appeal, Broussard asserts the following assignments of error:

A. Given the absence of critical discovery, the district court abused its discretion in refusing to continue the summary judgment hearing.

B. The district court erred in refusing to continue the summary judgment hearing where the plaintiff received less than the 30-day notice required by article 966(C)(1)(b) of the Code of Civil Procedure.

STANDARD OF REVIEW

The standard of review utilized by an appellate court when reviewing a trial

court’s grant of a motion for summary judgment is de novo. Duncan v. U.S.A.A. Ins.

Co., 06-363 (La. 11/29/06), 950 So.2d 544. Under this standard, the appellate court

uses the same criteria as the trial court in determining if summary judgment is

appropriate pursuant to La.Code Civ.P. art. 966. Id. The criteria enunciated in

La.Code Civ.P. art. 966(A)(3) provides that “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.” “A fact is ‘material’ when its existence or nonexistence may be

essential to [a] plaintiff’s cause of action under the applicable theory of recovery.”

Smith v. Our Lady of the Lake Hosp., Inc., 93-2512, p. 27 (La. 7/5/94), 639 So.2d

730, 751. Additionally, a fact is material if it potentially insures or precludes

recovery, affects a litigant’s ultimate success, or determines the outcome of the legal

dispute. Id.

Louisiana Code of Civil Procedure Article 966(D)(1) explains the mover’s

burden of proof on summary judgments as follows:

The burden of proof rests with the mover. Nevertheless, if the mover will not bear the burden of proof at trial on the issue that is before 2 the court on the motion for summary judgment, the mover’s burden on the motion does not require him to negate all essential elements of the adverse party’s claim, action, or defense, but rather to point out to the court the absence of factual support for one or more elements essential to the adverse party’s claim, action, or defense. 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.

DISCUSSION

In his second assignment of error, Broussard contends that the trial court erred

in refusing to continue the summary judgment hearing because he received less than

thirty-days’ notice in violation of La.Code Civ.P. art. 966(C)(1)(b). According to

Broussard, this article ensures that parties are given at least thirty-days’ notice of the

setting of a hearing on a motion for summary judgment. He asserts that this

mandatory pre-hearing notice was not afforded to him.

In opposition, Wet Tech Lighting contends that the article at issue states that

the time limits must be followed unless otherwise agreed to by all of the parties and

the court. It points to Broussard’s handling of the case, including the filing of an

opposition addressing the merits and appearing at the hearing to argue his position.

According to Wet Tech Lighting, Broussard’s foregoing actions reveal that no

prejudice occurred and that he waived any objection he may have had regarding the

timing of the hearing.

Notice of a hearing on a motion for summary judgment is discussed in

La.Code Civ.P. art. 966, as follows:

C. (1) Unless otherwise agreed to by all of the parties and the court: ....

(b) Notice of the hearing date shall be served on all parties in accordance with Article 1313(C) or 1314 not less than thirty days prior to the hearing.

3 On review, the record reveals that April 16, 2018 is when Broussard’s counsel

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Related

Duncan v. USAA Ins. Co.
950 So. 2d 544 (Supreme Court of Louisiana, 2007)
Lewis v. Old Republic Insurance Co.
226 So. 3d 557 (Louisiana Court of Appeal, 2017)

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Bradley Broussard v. Gulfport Energy Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bradley-broussard-v-gulfport-energy-corporation-lactapp-2019.