Caitlin Scott v. City of New Orleans by and Through the New Orleans Aviation Board D/B/A Louis Armstrong New Orleans International Airport

CourtLouisiana Court of Appeal
DecidedFebruary 18, 2026
Docket2025-CA-0513
StatusPublished
AuthorJudge Paula A. Brown

This text of Caitlin Scott v. City of New Orleans by and Through the New Orleans Aviation Board D/B/A Louis Armstrong New Orleans International Airport (Caitlin Scott v. City of New Orleans by and Through the New Orleans Aviation Board D/B/A Louis Armstrong New Orleans International Airport) 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
Caitlin Scott v. City of New Orleans by and Through the New Orleans Aviation Board D/B/A Louis Armstrong New Orleans International Airport, (La. Ct. App. 2026).

Opinion

CAITLIN SCOTT * NO. 2025-CA-0513

VERSUS * COURT OF APPEAL

CITY OF NEW ORLEANS BY * FOURTH CIRCUIT AND THROUGH THE NEW ORLEANS AVIATION BOARD * STATE OF LOUISIANA D/B/A LOUIS ARMSTRONG NEW ORLEANS ******* INTERNATIONAL AIRPORT

APPEAL FROM CIVIL DISTRICT COURT, ORLEANS PARISH NO. 2024-00745, DIVISION “F-14” Honorable Jennifer M Medley ****** Judge Paula A. Brown ****** (Court composed of Judge Daniel L. Dysart, Judge Sandra Cabrina Jenkins, Judge Paula A. Brown)

Bobby G. Hawkins Anthony D. Irpino IRPINO, AVIN & HAWKINS 2216 Magazine Street New Orleans, LA 70130

COUNSEL FOR PLAINTIFF/APPELLANT

Mindy Brickman Oscar McDuffie Gwin CHRISTOVICH & KEARNEY, LLP 601 Poydras Street Suite 2300 New Orleans, LA 70130

COUNSEL FOR DEFENDANT/APPELLEE

REVERSED; REMANDED WITH INSTRUCTIONS

FEBRUARY 18, 2026 PAB DLD SCJ

This case involves the issue of premises liability for a public entity.

Appellant, Caitlin Scott (“Ms. Scott”), appeals the district court’s May 28, 2025

judgment, which granted summary judgment in favor of Appellees, the City of

New Orleans by and through the New Orleans Aviation Board (“NOAB”)1 and

ACE Property and Casualty Insurance Company (“ACE”) (collectively,

“Defendants”), dismissing all of Ms. Scott’s claims with prejudice. For the reasons

that follow, we reverse the district court’s May 28, 2025 judgment, and remand the

matter for further proceedings consistent with this opinion.

FACTUAL AND PROCEDURAL HISTORY

On February 25, 2023, Ms. Scott was traversing Concourse C at Louis

Armstrong New Orleans International Airport (the “Airport”) located in Kenner,

Louisiana, to catch an outbound flight. At some point along her path, Ms. Scott

encountered a slick portion of the walkway, whereupon she slipped and fell.

Surveillance video from that day reveals that approximately nine minutes prior to

Ms. Scott’s fall, another Airport patron spilled some sort of clear liquid from a cup.

1 NOAB is an unattached municipal board of the City of New Orleans and is charged with the

administration, operation, and maintenance of Louis Armstrong International Airport. See La. R.S. 2:131 et seq. See also La. R.S. 2:351.

1 The patron’s companion then walked to a nearby coffee-shop counter where she

briefly interacted with the shop’s employee and appeared to retrieve a new cup and

pour the remaining liquid from the original cup into the replacement cup. Shortly

afterwards, the two left the scene without cleaning up any liquid that might have

remained on the floor. According to a sworn affidavit signed by Michelle Wilcut

(“Ms. Wilcut”)—Deputy Director and Chief Customer Service Manager of the

Airport on the day of the incident—Ms. Scott’s fall was reported to NOAB via the

Airport’s AVCOM2 communication system. Ms. Wilcut further attested that

within the nine minutes between the spill and Ms. Scott’s fall, the spill was not

reported to NOAB.

On January 26, 2024, Ms. Scott filed a Petition for Damages, naming as

defendants NOAB and its liability insurer, ACE Property and Casualty Company.

In the petition, she alleged that she sustained injuries from her fall caused by a

hazardous and dangerous substance and that NOAB had been negligent by failing

to properly maintain the Airport by keeping it free from such defects and by failing

to warn her of the dangerous condition. Following, on April 17, 2024, Defendants

filed an answer, generally denying Ms. Scott’s allegations and any liability on their

part. A little over six months later, on November 4, 2024, Defendants jointly filed

a motion for summary judgment. In this motion, Defendants argued that Ms. Scott

would be unable to meet her burden of proof at trial that NOAB had either actual

or constructive notice of the hazardous condition, as required for a finding of

liability on the part of a public entity, pursuant to La. R.S. 9:2800.3 In response, on

2 AVCOM is the department established by the Aviation Board that has responsibility for Airport

communications, emergency dispatch, and other related functions. 3 Louisiana Revised Statutes 9:2800 will be more fully discussed infra.

2 February 14, 2025, Ms. Scott retained Neil Hall, PhD (“Mr. Hall”), a licensed

professional engineer, architect, landscape architect and interior designer, to

inspect the walkway where she fell and to provide an expert report of his findings.

Mr. Hall delivered this report to Ms. Scott on April 10, 2025.

On April 25, 2025, Ms. Scott filed an Expedited Motion to Continue

Hearing on Defendant’s Motion for Summary Judgment Due to Insufficient

Discovery. She argued in her memorandum in support of the motion that La.

C.C.P. art. 966(A)(3) mandates that summary judgment may only be granted

“[a]fter an opportunity for adequate discovery,” and that pursuant to La. C.C.P. art.

966(C)(2), “[f]or good cause shown, the court may order a continuance of the

hearing.” The district court denied the expedited motion on April 28, 2025, with a

notation that the matter needed to be set for contradictory hearing. The record on

appeal does not contain a request or motion to set such a hearing. Nevertheless,

Ms. Scott filed an opposition to the motion for summary judgment on April 30,

2025, in which she re-urged the argument that there had been inadequate time for

discovery and attached the sworn affidavit and expert report of Mr. Hall. On May

12, 2025, Defendants filed a reply brief, wherein it was explained that Ms. Scott

had already been the beneficiary of two unopposed motions for continuance. The

record confirms that the original hearing on the motion for summary judgment was

set for December 19, 2024. That hearing was continued until February 6, 2025,

which hearing was also continued until it was finally heard on May 15, 2025.

Ruling from the bench, the district court granted NOAB’s motion for summary

judgment, finding that Ms. Scott’s opposition contained nothing but conclusory

3 allegations, there had been ample time for discovery and Ms. Scott had not

previously raised any discovery issues to that court. A written judgment

dismissing all of Ms. Scott’s claims against Defendants with prejudice was signed

on May 28, 2025, and mailed on June 5, 2025. This timely appeal followed.

DISCUSSION

Ms. Scott has assigned four alleged errors for our review,4 which we have

summarized and narrowed to two principal issues: (1) the district court erred when

it granted summary judgment in favor of NOAB, finding that no genuine issues of

material fact remained; and (2) the district court erred when it denied Ms. Scott’s

motion to continue to conduct additional discovery.

Summary Judgment

“It is well-settled law that ‘[t]his Court reviews the granting of ‘[a] summary

judgment on appeal de novo, using the same criteria that govern the [district]

court’s determination of whether summary judgment is appropriate.’” Cloud v.

Gibson, 23-0435, p. 10 (La. App. 4 Cir. 7/30/24), 399 So.3d 604, 611 (quoting

4 Specifically, Ms. Scott asserts that:

1. It was error for the [district] court to deny Plaintiffs motion to continue and instead rule on Defendants’ motion for summary judgment, when Plaintiff was not permitted to depose Defendants’ corporate representative, nor was she permitted to depose Defendants’ employee/s tasked with monitoring live CCTV footage, and the employee who responded and cleaned up the spill.

2.

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Caitlin Scott v. City of New Orleans by and Through the New Orleans Aviation Board D/B/A Louis Armstrong New Orleans International Airport, Counsel Stack Legal Research, https://law.counselstack.com/opinion/caitlin-scott-v-city-of-new-orleans-by-and-through-the-new-orleans-lactapp-2026.