Celeste Reed, Mother and Tutrix of A.M.C. v. Geico Casualty Company

CourtLouisiana Court of Appeal
DecidedFebruary 5, 2025
DocketCA-0024-0381
StatusUnknown

This text of Celeste Reed, Mother and Tutrix of A.M.C. v. Geico Casualty Company (Celeste Reed, Mother and Tutrix of A.M.C. v. Geico Casualty 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
Celeste Reed, Mother and Tutrix of A.M.C. v. Geico Casualty Company, (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

24-381

CELESTE REED, MOTHER AND TUTRIX OF A.M.C.

VERSUS

GEICO CASUALTY COMPANY

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. 20230065 HONORABLE SCOTT J. PRIVAT, DISTRICT JUDGE

WILBUR L. STILES JUDGE

Court composed of Elizabeth A. Pickett, Ledricka J. Thierry, and Wilbur L. Stiles, Judges.

AFFIRMED. Tracy P. Curtis The Glenn Armentor Law Corp. 300 Stewart Street Lafayette, LA 70501 (337) 233-1471 COUNSEL FOR PLAINTIFF/APPELLANT: Celeste Reed, mother and tutrix of A.M.C.

Steven M. Mauterer Nicholas P. Arnold Blue Williams, LLC 3421 N. Causeway Boulevard, Suite 900 Metairie, LA 70002 (504) 831-4091 COUNSEL FOR DEFENDANT/APPELLEE: GEICO Casualty Company STILES, Judge.

The trial court entered summary judgment in favor of GEICO Casualty

Company after determining that the policy it issued to Corey Kothenbeutel did not

offer coverage for his permissive use of an automobile that he co-owned with the

decedent which was not identified in the subject policy. Plaintiff Celeste Reed

appeals. For the following reasons, we affirm.

FACTUAL AND PROCEDURAL HISTORY

Plaintiff filed a Petition for Declaratory Judgment and Damages on behalf of

the minor child born to her and to Johnnie Keith Cope. Mr. Cope died from wounds

sustained in a January 17, 2022 automobile accident when he was travelling as a

passenger in a 2016 Ram 1500 which was co-owned and being driven by Mr.

Kothenbeutel. By the petition, Plaintiff pursued a survival action and sought

damages associated with wrongful death.

Plaintiff named GEICO Casualty Company as a defendant1 and alleged that

two policies issued by the insurer provided coverage for the identified claims.

Plaintiff first identified GEICO policy no. 6009-98-10-66 issued to Mr. Cope and

Ms. Reed for the 2016 Ram. Plaintiff alleged that coverage was provided for Mr.

Kothenbeutel’s permissive use of the 2016 Ram. GEICO does not dispute that the

Cope policy provides coverage in that regard.

Rather, the present proceeding involves Plaintiff’s attempt to recover

secondary coverage under GEICO policy no. 6004-47-96, a policy issued to Mr.

1 Plaintiff named the “estate of Corey Kothenbeutel” as an additional defendant pursuant to La.Code Civ.P. art. 1880 (“When declaratory relief is sought, all persons shall be made parties who have or claim any interest which would be affected by the declaration, and no declaration shall prejudice the rights of persons not parties to the proceeding.”). Kothenbeutel. The Kothenbeutel policy listed only a 2017 Ram 2500, a vehicle not

involved in the fatal accident.

Plaintiff asserted that, although GEICO had “taken the position that its policy

written to Kothenbeutel does not apply under these facts[,]” the insurer failed to

articulate its “coverage denial position” and to provide supporting documentation.

Plaintiff therefore asked the trial court “to declare the rights of the parties relative

to” the Kothenbeutel policy and to declare that it provides coverage to Plaintiff for

the crash in the 2016 Ram.

In its Answer, GEICO denied coverage under the Kothenbeutel policy and

explained that it had received information indicating that Mr. Kothenbeutel was a

co-owner of the 2016 Ram “occupied by Cope at the time of the subject accident.”

The Kothenbeutel policy, however, listed only the 2017 Ram, not the 2016 Ram.

GEICO therefore asserted that the 2016 Ram, both “owned” and operated by Mr.

Kothenbeutel at the time of accident, did not meet the definition of an “owned auto”

under the Kothenbeutel policy. GEICO further maintained that the Kothenbeutel

policy did not afford uninsured/underinsured motorist coverage as Mr. Kothenbeutel

had rejected that coverage.

GEICO thereafter filed a motion for summary judgment seeking a declaration

that the Kothenbeutel policy offers no coverage for Plaintiff’s claims. In support of

its position that Mr. Kothenbeutel and Mr. Cope co-owned the 2016 Ram, GEICO

attached records of the men’s purchase of the vehicle and its title history. GEICO

also attached the Kothenbeutel policy, for the proposition that, despite his ownership

interest in the vehicle, the 2016 Ram was not listed in the policy nor was a premium

charged for its coverage.

2 Plaintiff opposed the motion, asserting that the Kothenbeutel policy extended

coverage for his “permissive use” of the vehicle in light of what she maintains was

GEICO’s inadequate evidence regarding ownership. Plaintiff argued that, rather than

ownership, the evidence related only to Mr. Kothenbeutel’s involvement in the

financing of the vehicle. She further maintained that GEICO’s policy otherwise

failed to define either “ownership” or “co-ownership[.]” Plaintiff suggested that this

failure to define the terms rendered the policy vague and required the court to

construe the policy in favor of coverage.

Following oral arguments, the trial court determined that Mr. Kothenbeutel

was “half-owner” of the 2016 Ram and, therefore, the Kothenbeutel policy did not

apply to the accident. By the resulting May 17, 2024 judgment, the trial court granted

GEICO’s motion for summary judgment and dismissed Plaintiff’s claims with

prejudice.

Plaintiff appeals, assigning the following as error:

[1.] The district court erred in granting Geico’s summary judgment: A motion based on the assertion of a lack of coverage under an insurance policy must not be rendered when there is a reasonable interpretation of the policy that affords coverage. And here, mover’s policy lacks a definition of ownership relative to its permissive user coverage for a non-owned auto. Utilizing the Civil Law view of ownership that looks beyond mere title to a policy’s missing definition of ownership results in the reasonable interpretation that the mere co-signed title to a vehicle does not defeat permissive use coverage.

[2.] Given that true ownership derives not from a title, but from the right to possess and use of a thing, and because it is only through possession that one can exercise the right of enjoyment, the district court erred in apparently determining that title in one’s name alone conveyed ownership sufficient to extend permissive use coverage.

[3.] Procedurally, an insurance company seeking summary dismissal and seeking to shift the burden of proof, must first illustrate a lack of evidence supporting one of the elements of plaintiff’s trial

3 burden of proof, and in this case mover failed to point to any absence of proof thus to the extent the district court found that plaintiff had the burden of proof it erred.

DISCUSSION

Summary Judgment

Louisiana Code of Civil Procedure Article 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.” The burden of proving entitlement to

summary judgment rests with the mover. La.Code Civ.P. art. 966(D)(1). If, however,

the mover will not bear the burden of proof at trial on the matter at issue, the mover

is not required 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.” Id.

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Celeste Reed, Mother and Tutrix of A.M.C. v. Geico Casualty Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/celeste-reed-mother-and-tutrix-of-amc-v-geico-casualty-company-lactapp-2025.