Cheniere Construction, Inc. v. The State of Louisiana through the Department of Revenue and Taxation

CourtLouisiana Court of Appeal
DecidedSeptember 18, 2020
Docket2019CA1471
StatusUnknown

This text of Cheniere Construction, Inc. v. The State of Louisiana through the Department of Revenue and Taxation (Cheniere Construction, Inc. v. The State of Louisiana through the Department of Revenue and Taxation) 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
Cheniere Construction, Inc. v. The State of Louisiana through the Department of Revenue and Taxation, (La. Ct. App. 2020).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

2019 CA 1471

CHENIERE CONSTRUCTION, INC.

VERSUS

THE STATE OF LOUISIANA THROUGH THE DEPARTMENT OF REVENUE AND TAXATION

Decision Rendered. SEP 18 2020

APPEALED FROM THE 19th JUDICIAL DISTRICT COURT EAST BATON ROUGE PARISH, LOUISIANA DOCKET NUMBER C- 674, 650, DIVISION 22

HONORABLE TIMOTHY E. KELLEY, JUDGE

Timothy K. Lamy Attorney for Plaintiff/Appellant New Orleans, Louisiana Cheniere Construction, Inc.

Jeff Landry Attorneys for Defendants/ Appellees Attorney General State of Louisiana through the and Department of Revenue and Taxation Wm. David Coffey and Kimberly L. Robinson Kathryn M. Calmes Assistant Attorneys General Baton Rouge, Louisiana

BEFORE: WDONALD, THERIOT, and CHUTZ, J]. McDONALD, J.

A taxpayer appeals a judgment granting a peremptory exception of no cause of

action and dismissing its petition for tort damages against the Louisiana Department of

Revenue and Taxation and its Secretary, Kimberly L. Robinson. We affirm.

FACTUAL AND PROCEDURAL BACKGROUND

In December 2014, the Department issued a Notice of Assessment to Cheniere

Construction, Inc. for $ 320, 664. 43 in sales and use taxes, interest, and penalties due for

the filing periods of March 31, 2009 through September 30, 2012. Cheniere appealed the

assessment to the Louisiana Board of Tax Appeals. In June 2016, the Department and

Cheniere reached a consent agreement, whereby Cheniere agreed to pay $ 139, 349. 84 in

taxes for the subject period. According to Cheniere, the agreement was silent as to

interest and penalties, but the parties agreed that the Department's collection department

would address these issues. On June 16, 2016, the Board of Tax Appeals issued an order

dismissing Cheniere's appeal with prejudice.

In October 2016, the Department issued a revised Notice of Assessment to

Cheniere for $ 139, 349. 84 in taxes, plus $ 59, 266. 98 in interest and $ 25, 659. 10 in

delinquent filing penalties. Cheniere disputed the inclusion of the interest and penalties,

claiming that it had legitimately challenged the past due taxes, and that its delay in paying

the past due taxes was due to the Department's unreasonably lengthy audit of Cheniere's

tax returns. On November 3, 2016, Cheniere sent the Department a $ 139, 349. 84 check

with a cover letter stating that the check represented a " full satisfaction and compromise"

of all sales taxes and any related interest and penalties Cheniere owed. Cheniere' s letter

also provided that, if the Department did not wish to accept the tendered amount in full

satisfaction of Cheniere' s debt, the Department should return the check to Cheniere. The

Department thereafter negotiated Cheniere' s check.

About a year later, in October 2017, the Department seized $ 97, 491. 57, from

Cheniere' s bank account, the amount apparently representing the outstanding interest and

penalties owed. Within a year of the Department's seizure, in October 2018, Cheniere

filed the instant petition for damages against the Department; and, in December 2018,

2 Cheniere filed an amending petition adding Ms. Robinson as a defendant. Cheniere

alleged that its $ 139, 349. 84 payment was a full accord and satisfaction, i. e., a

compromise under our civilian law, of Cheniere' s debt to the State of Louisiana, and the

Department' s seizure of Cheniere' s bank account funds was a wrongful seizure entitling

Cheniere to tort damages.

The Department and Ms. Robinson ( collectively, Department) responded by filing

exceptions of res judicata and no cause of action seeking dismissal of Cheniere' s suit.

After a hearing, the district court signed a judgment on July 24, 2019, denying the JOW

exception of res judicata, granting the exception of no cause of action, and dismissing

Cheniere' s suit against the Department with prejudice. The district court reasoned that

Cheniere had not stated a cause of action, because it failed to allege proper compliance

with Louisiana tax law.

Cheniere appeals the adverse judgment, essentially contending the district court

erred in characterizing its suit as a tax protest suit under Louisiana tax law, rather than a

wrongful seizure suit under Louisiana tort law. Cheniere argues that it has alleged

sufficient facts to allege a wrongful seizure cause of action against the Department.

DISCUSSION

The peremptory exception of no cause of action questions whether the law affords

the plaintiff any remedy under the allegations of the petition.' The exception is triable

solely on the face of the petition and any attached written exhibits. La. C. C. P. arts. 853

and 931; Agrifund, LLC v. Radar Ridge Planting Co., Inc., 19- 1528 ( La. 11/ 25/ 19), 283

So. 3d 492 ( per curiam); Baca v. Sabine River Authority, 18- 1046 ( La. App. 1 Cir.

12/ 27/ 18), 271 So. 3d 223, 227. The court must presume all well -pleaded facts are true,

must make all reasonable inferences in favor of the non- moving party, and must resolve

any doubts in favor of the petition' s sufficiency. The exceptor bears the burden of

1 Attempts to re -open issues related to final assessments have arisen in a variety of procedural postures, and they have been variously defeated via exceptions of no cause of action, no right of action, or lack of subject matter jurisdiction. See, e.g., Devon Energy Production Co., L. P. v. Bridges, 12- 0809 ( La. App. 1 Cir. 6/ 3/ 13), 120 So. 3d 303; Price v, Secretary, Dept. of Revenue and Taxation, State of La, 95- 877 ( La. App. 3 Cir. 12/ 6/ 95), 664 So. 2d 802; Shields & Shields, APLC v. State/ La. Dept. of Revenue, 14- 0693 ( La. App. 1 Cir. 3/ 14/ 15), 168 So. 3d 877. As here, where the petition shows there was a final assessment that was neither appealed nor fully paid within the applicable period before it became final, and the taxpayer files suit seeking a remedy under civil code principles, rather than tax laws, then an exception of no cause of action is proper. See Majestic Medical Solutions, LLC v. Secretary, Louisiana Department of Revenue, No. 9449C ( La. Bd. of Tax App. 10/ 10/ 17), 2017 WL 5985762 * 4, n. 6. 3 showing that the plaintiff has not stated a cause of action. The appellate court performs a

de novo review of a district court's ruling on an exception of no cause of action. Baca,

271 So. 3d at 227.

The power of taxation is vested in the legislature. La. Const. art. VII, § 1. Laws

regulating the collection of taxes are sui generis and comprise a system to which general

provisions of the law have little, if any, relevance. Accord St. Martin v. State, 09- 0935 ( La.

12/ 1/ 09), 25 So. 3d 736, 739 n. 5 ( noting that Louisiana courts have routinely rejected

attempts to assert refund claims against a taxing authority under La. C. C. art. 2299, et

seq., addressing payment of a thing not due); also see Mallard Bay Drilling, Inc. v.

Kennedy, 04- 1089 ( La.

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

Related

St. Martin v. State
25 So. 3d 736 (Supreme Court of Louisiana, 2009)
Avenal v. State
886 So. 2d 1085 (Supreme Court of Louisiana, 2004)
Mallard Bay Drilling, Inc. v. Kennedy
914 So. 2d 533 (Supreme Court of Louisiana, 2005)
Angela Roberson-King v. State of LA Workforce Cmsn
904 F.3d 377 (Fifth Circuit, 2018)
Devon Energy Production Co. v. Bridges
120 So. 3d 303 (Louisiana Court of Appeal, 2013)
Shields & Shields, APLC v. State/LA Department of Revenue
168 So. 3d 877 (Louisiana Court of Appeal, 2015)
Price v. Secretary, Department of Revenue & Taxation
664 So. 2d 802 (Louisiana Court of Appeal, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
Cheniere Construction, Inc. v. The State of Louisiana through the Department of Revenue and Taxation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cheniere-construction-inc-v-the-state-of-louisiana-through-the-lactapp-2020.