Charles Guillory and Tammy Guillory v. Louisiana Farm Bureau Casualty Insurance Co.

CourtLouisiana Court of Appeal
DecidedOctober 4, 2023
DocketCA-0022-0634
StatusUnknown

This text of Charles Guillory and Tammy Guillory v. Louisiana Farm Bureau Casualty Insurance Co. (Charles Guillory and Tammy Guillory v. Louisiana Farm Bureau Casualty Insurance Co.) 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
Charles Guillory and Tammy Guillory v. Louisiana Farm Bureau Casualty Insurance Co., (La. Ct. App. 2023).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

22-634

CHARLES GUILLORY AND TAMMY GUILLORY

VERSUS

LOUISIANA FARM BUREAU CASUALTY INSURANCE COMPANY

**********

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NUMBER 2021-1254 HONORABLE CLAYTON A. DAVIS, DISTRICT JUDGE

SHARON DARVILLE WILSON JUDGE

Court composed of Shannon J. Gremillion, Van H. Kyzar, and Sharon Darville Wilson, Judges.

AFFIRMED. Michael K. Cox Somer G. Brown COX, COX, FILO, CAMEL, WILSON & BROWN, LLC 723 Broad Street Lake Charles, Louisiana 70601 (337) 436-6611 Counsel for Plaintiffs/Appellees: Charles Guillory and Tammy Guillory

Charles C. Garrison Staci Know Villemarette Lauren Camel Begnaud CAFFERY, OUBRE, CAMPBELL & GARRISON, LLP 100 East Vermillion Street, Suite, 201 Lafayette, Louisiana 70501 (337) 446-2442 Counsel for Defendant/Appellant: Louisiana Farm Bureau Casualty Insurance Company

Wayne J. Lee Heather S. Lonian STONE PIGMAN WALTHER WITTMANN, LLC 909 Poydras Street, Suite 3150 New Orleans, Louisiana 70112 (504) 581-3361 Counsel for Defendant/Appellant: Louisiana Farm Bureau Casualty Insurance Company WILSON, Judge.

Louisiana Farm Bureau Casualty Insurance Company (LFBC) appeals

several adverse rulings in this suit for breach of contract, penalties, and attorney

fees regarding LFBC’s handling of a claim for damages resulting from Hurricanes

Laura and Delta. For the reasons that follow, we affirm the trial court’s rulings,

the jury’s verdict and the judgment signed in accordance therewith, and the trial

court’s award of costs.

I.

ISSUES

This appeal presents the following issues:

1. Whether the trial court erred in denying LFBC’s motion to recuse Judge Davis and/or in declining to refer the motion to an ad hoc judge.

2. Whether the trial court correctly instructed the jury as to the legal standard for claims asserted under La.R.S. 22:1973 and/or 22:1892.

3. Whether the jury committed manifest error in finding that each and every payment by LFBC to Plaintiffs was not timely made within thirty days of receiving satisfactory proof of loss.

4. Whether the trial court erred in permitting Plaintiffs to introduce and argue that evidence concerning their withdrawn additional living expenses (ALE) claim as evidence of their alleged mental anguish, while simultaneously preventing LFBC from introducing countervailing evidence on this issue.

5. Whether the trial court erred in awarding costs that are allegedly not recoverable by law.

II.

FACTS AND PROCEDURAL HISTORY

LFBC issued a homeowner’s policy covering the residential property owned

by Charles and Tammy Guillory and located on Oak Park Boulevard in Lake

Charles, Louisiana. The policy had coverage limits of $169,000.00. The property was significantly damaged by Hurricane Laura on August 27, 2020, and by

Hurricane Delta on October 9, 2020.

On or about August 31, 2020, Plaintiffs initiated a claim under their

homeowners policy. LFBC sent its adjuster, Corey Daigle (Daigle), to inspect the

property on September 11, 2020. Plaintiffs contend that this is the date when

LFBC had sufficient proof of loss. Following the inspection, Daigle prepared an

estimate that calculated the replacement cost value of the residence at $51,721.61.

After Hurricane Delta made landfall on October 9, 2020, Plaintiffs contacted

LFBC and reported additional damage to their property. On October 19, 2020,

LFBC adjuster Kris Trahan (Trahan) inspected the property. Daigle and Trahan

consulted with each other regarding their inspections of the property, and Daigle

revised his earlier estimate.

LFBC made the following payments:

$44,370.83 on September 16, 2020 (damages caused by Laura) $15,569.77 on October 19, 2020 (additional damages caused by Delta) $5,440.86 on December 1, 2020 (supplement to roof replacement cost) $25,955.98 on December 8, 2020 (remediation services) $14,000.00 on December 10, 2020 (repairs to air conditioner) $63,662.56 on August 19, 2021 (remaining unpaid dwelling limit) $51,721.61 on October 5, 2021 (contents claim)

Plaintiffs retained the services of a public adjuster, Kermit Sonnier (Sonnier).

Sonnier estimated the replacement value cost at $198,441.66. LFBC then assigned

a claims representative, Chris Fontenot. Fontenot requested copies of any

estimates that Sonnier prepared on behalf of Plaintiffs. In the course of trying to

obtain these estimates, Fontenot was informed that Plaintiffs were represented by

counsel.

On March 31, 2021, Plaintiffs filed a petition for breach of contract,

penalties and attorney’s fees pursuant to La.R.S. 22:1973 and 22:1892. They

alleged that LFBC failed to pay all amounts owed under the policy within sixty

2 days after LFBC received satisfactory proof of loss and underpaid their claims.

Plaintiffs alleged that this failure resulted in significant delays in their being able to

return to their home, thereby causing them severe anxiety, mental anguish, and

emotional distress. They further alleged that LFBC failed to compensate them for

their additional living expenses, but this claim was later dismissed.

On May 4, 2022, the 1442 deposition of LFBC was to take place. Plaintiffs

got a subpoena requiring LFBC to produce certain financial documents that were

not listed on the original notice of deposition. LFBC moved to quash the subpoena.

The trial court denied the motion, and LFBC applied for writs to this court. This

court denied the request for a stay and denied the writ application. Guillory v. La.

Farm Bureau Cas. Ins. Co., 22-286 (La.App. 3 Cir. 5/11/22) (unpublished writ

decision), writ denied, 22-758 (La. 5/11/22). The Louisiana Supreme Court also

denied the request for stay and denied writs.

On May 3, 2022, LFBC filed a motion to recuse Judge Davis based on

certain adverse rulings and based on the assertion that Plaintiffs’ attorneys had

contributed 72.73% of the total contributions to Judge Davis’ campaign to get

elected to the Third Circuit in November of 2022. Judge Davis denied the motion

to recuse as untimely. No writ applications were taken with regard to the denial of

the motion to recuse.

The matter proceeded to trial by jury on May 19, 2022. The jury found in

favor of Plaintiffs. The jury specifically found that the payments (except those on

September 16, 2020, and October 5, 2021) were not made within thirty days of

LFBC’s receipt of satisfactory proof of loss and that such failure was arbitrary and

capricious. The jury found those payments were also not paid within sixty days of

satisfactory proof of loss. The jury awarded $65,000.00 to each Plaintiff for

mental anguish and emotional distress and statutory penalties in the amount of

3 $260,000.00. Plaintiffs’ counsel was awarded attorney’s fees in the amount of

$152,978.60, and Farm Bureau was taxed with all costs. On July 5, 2022, the trial

court signed a judgment in accordance with the jury’s verdict. Farm Bureau now

appeals.

III.

LAW AND DISCUSSION

Motion to Recuse

We must first determine whether the trial court correctly denied LFBC’s

motion to recuse Judge Davis as untimely. Louisiana Code of Civil Procedure

Article 154(A) provides that the motion to recuse must be filed:

no later than thirty days after discovery of the facts constituting the ground upon which the motion is based, but in all cases prior to the scheduling of the matter for trial.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Stobart v. State Through DOTD
617 So. 2d 880 (Supreme Court of Louisiana, 1993)
Orellana v. LOUISIANA CITIZENS PROP. INS.
972 So. 2d 1252 (Louisiana Court of Appeal, 2007)
Libersat v. J & K TRUCKING, INC.
772 So. 2d 173 (Louisiana Court of Appeal, 2000)
Urrate v. Argonaut Great Cent. Ins. Co.
881 So. 2d 787 (Louisiana Court of Appeal, 2004)
J.R.A. Inc. v. Essex Insurance Co.
72 So. 3d 862 (Louisiana Court of Appeal, 2011)
Aghighi v. Louisiana Citizens Property Insurance Corp.
119 So. 3d 930 (Louisiana Court of Appeal, 2013)
Aghighi v. Louisiana Citizens Insurance Corp.
124 So. 3d 1102 (Supreme Court of Louisiana, 2013)
Reynolds v. Louisiana Department of Transportation
194 So. 3d 56 (Louisiana Court of Appeal, 2016)
Butler v. Louisiana Mutual Medical Insurance Co.
195 So. 3d 570 (Louisiana Court of Appeal, 2016)
Riddle v. Premier Plaza of Monroe, L.L.C.
216 So. 3d 170 (Louisiana Court of Appeal, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Charles Guillory and Tammy Guillory v. Louisiana Farm Bureau Casualty Insurance Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/charles-guillory-and-tammy-guillory-v-louisiana-farm-bureau-casualty-lactapp-2023.