Cain v. Altec Industries, Inc.

236 F. App'x 965
CourtCourt of Appeals for the Fifth Circuit
DecidedJune 22, 2007
Docket06-30619
StatusUnpublished
Cited by2 cases

This text of 236 F. App'x 965 (Cain v. Altec Industries, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cain v. Altec Industries, Inc., 236 F. App'x 965 (5th Cir. 2007).

Opinion

PER CURIAM: *

Plaintiffs, Francis and Doris Cain, individually and on behalf of their minor child, Matthew Cain, and Plaintiff Intervenor Employers Mutual Casualty Company (“Employers”), appeal a district court order granting the motion for summary judgment of Defendant Intervenor Washington St. Tammany Electric Cooperative, Inc. (“WST”). Because we conclude Mississippi law applies to this dispute, we REVERSE and REMAND.

I. FACTUAL AND PROCEDURAL BACKGROUND

Plaintiff Francis Cain (“Cain”), a Mississippi resident, was employed by Carson Line Service, Inc. (“Carson”), a Mississippi Corporation. Carson entered into a contract with WST, a Louisiana corporation, in which Carson agreed to clear rights-of-way for WST. Pursuant to this agreement, Cain was trimming trees along an electric power line in St. Tammany Parish, Louisiana when the aerial bucket being used by Cain came into contact with an energized power fine, causing Cain severe injuries. The electric power line was owned by WST. Following his injury, Cain received workers’ compensation benefits under Mississippi’s workers’ compensation law through Carson’s carrier, Employers.

Cain and his wife, individually and on behalf of their minor child (the “Cains”), brought this suit seeking damages from Altec Industries, Inc. (“Altec”), the manufacturer of the aerial bucket, and WST. WST filed a third party claim against Carson for defense and indemnity. The Cains then dismissed their action against Altec, leaving WST as the only defendant. Employers subsequently intervened, asserting its subrogation rights for workers’ compensation benefits paid to Cain.

WST filed a motion for summary judgment claiming tort immunity based on the statutory employer doctrine in Louisiana’s workers’ compensation law. In response, the Cains and Employers argued that their case was an “exceptional case,” pursuant to La. Civ.Code Ann. art. 3547, and thus, the substantive law of Mississippi governed their claim. The district court rejected this argument and granted WST’s motion, concluding that Louisiana law ap *967 plied. The Cains and Employers timely filed this appeal.

II. Standard of Review

We review a district court’s choice-of-laws determination de novo. 1 We give no deference to the district court’s determination of state law. 2

Federal courts sitting in diversity must apply the choice-of-laws provisions of the state in which they sit. 3 Thus, we must apply Louisiana’s choice-of-laws principles to determine which state’s substantive law will apply.

III. Discussion

Prior to conducting a choice-of-laws analysis, we must first determine whether the laws of Louisiana and Mississippi conflict. 4 If the laws of the states do conflict, only then is it necessary for us to conduct a conflicts analysis to determine which state’s law should apply.

A. Is there a conflict of laws?

The contract between Cain and WST contained a provision specifically recognizing WST as a statutory employer of Carson’s employees. 5

Under Louisiana law, a written contract between a principal and contractor recognizing the principal as the statutory employer of the contractor’s employees is valid and enforceable. 6 As a result, under Louisiana law, WST is immune from civil tort liability. 7

However, unlike Louisiana, Mississippi law does not recognize and will not enforce any contractual provision seeking to give tort immunity to a principal who is sued by a contractor’s employees unless the principal has the legal obligation under the Mississippi Workers’ Compensation Act (the “Act”) to secure compensation for that contractor’s employees. 8 Under Mississippi law, an owner is not a statutory employer, and thus, has no obligations under the Act. 9 As a result, since WST was the own *968 er of the electric power line, it is not a statutory employer of Cain under Mississippi law and is not immune from liability. 10

Accordingly, there is a substantive difference between Louisiana and Mississippi law necessitating a choice-of-laws determination.

B. Choice of laws

We will apply Louisiana’s choice-of-laws provisions, found in Book IV of the Louisiana Civil Code, to resolve the choice-of-laws issue in this case.

The issue of whether WST is immune from tort liability is an issue of loss distribution and financial protection governed by La. Civ.Code Ann. art. 3544. 11 Therefore, we begin our analysis with article 3544, which provides, in relevant part:

Issues pertaining to loss distribution and financial protection are governed, as between a person injured by an offense or quasi-offense and the person who caused the injury, by the law designated in the following order:
(2) If, at the time of the injury, the injured person and the person who caused the injury were domiciled in different states: (a) when both the injury and the conduct that caused it occurred in one of those states, by the law of that state;____

Under the mechanical rule of article 3544, we would apply Louisiana law because, at the time of the injury, Cain, a Mississippi domiciliary, and WST, a Louisiana corporation, were domiciled in different states, and both the injury and the conduct that caused it occurred in one of those states, i.e., Louisiana. Accordingly, based on article 3544, WST would be entitled to the statutory employer tort immunity afforded it under Louisiana law.

However, article 3547 provides an exception to article 3544 to be used when the mechanical rule of article 3544 yields an inappropriate result. 12 Under La. Civ. Code Ann. art. 3547, this exception is applicable when

from the totality of the circumstances of an exceptional case, it is clearly evident under the principles of Article 3542, that the policies of another state would be more seriously impaired if its law were not applied to the particular issue. In such event, the law of the other state shall apply.

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236 F. App'x 965, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cain-v-altec-industries-inc-ca5-2007.