Christian Schools, Inc. d/b/a John Curtis Christian School v. Louisiana High School Athletic Association Eddie Bonine and B.J. Guzzardo, Jr.

CourtLouisiana Court of Appeal
DecidedMay 18, 2022
Docket2020CA0762
StatusUnknown

This text of Christian Schools, Inc. d/b/a John Curtis Christian School v. Louisiana High School Athletic Association Eddie Bonine and B.J. Guzzardo, Jr. (Christian Schools, Inc. d/b/a John Curtis Christian School v. Louisiana High School Athletic Association Eddie Bonine and B.J. Guzzardo, Jr.) 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
Christian Schools, Inc. d/b/a John Curtis Christian School v. Louisiana High School Athletic Association Eddie Bonine and B.J. Guzzardo, Jr., (La. Ct. App. 2022).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

NO. 2020 CA 0762 R

r CHRISTIAN SCHOOLS, INC. D/ B/ A JOHN CURTIS CHRISTIAN SCHOOL

VERSUS

LOUISIANA HIGH SCHOOL ATHLETIC ASSOCIATION, EDDIE BONINE AND B. J. GUZZARDO, JR.

Judgment Rendered.

MAY 18 2022

Appealed from the 19th Judicial District Court In and for the Parish of East Baton Rouge State of Louisiana Case No. 654874

The Honorable Donald R. Johnson, Judge Presiding

Gilbert V. Andry, IV Counsel for Plaintiff/Appellant New Orleans, Louisiana Christian Schools, Inc. d/ b/ a John Curtis Christian School Walter M. Sanchez Lake Charles, Louisiana

Everett R. Rineran New Orleans, Louisiana

Mark D. Boyer Counsel for Defendants/ Appellees Diana L. Tonagel Louisiana High School Athletic Denham Springs, Louisiana Association, Eddie Bonine and B. J. Guzzardo, Jr.

BEFORE: THERIOT, WOLFE, AND HESTER, JJ. THERIOT, J.

This appeal, involving a judgment dismissing the plaintiff' s suit on

exceptions of lack of subject matter jurisdiction and no cause of action, is before us

on remand from the supreme court. For the reasons set forth herein, we affirm.

FACTS AND PROCEDURAL HISTORY

Plaintiff, Christian Schools, Inc., d/ b/ a John Curtis Christian School (" John

Curtis"), filed a suit for damages against the Louisiana High School Athletic

Association, Inc. (" LHSAA"), LHSAA Executive Director Eddie Bonine, and

LHSAA employee Buster John Guzzardo, Jr. ( collectively " the LHSAA

defendants"), on January 30, 2017. This suit arose from a determination by the

LHSAA that John Curtis had violated LHSAA rules on recruiting and the resulting imposition of penalties.' In its petition, John Curtis alleged that the LHSAA

defendants " intentionally and or negligently punish[ ed], defame[ d] and violate[ d]

the due process and equal protection rights of John Curtis Christian School." In

addition to monetary damages, John Curtis sought to have the trial court overturn

the LHSAA' s finding that a recruiting violation occurred and reinstate its forfeited

football wins.

The LHSAA defendants raised an exception of lack of subject matter

jurisdiction in their answer to the petition, noting that under applicable

jurisprudence, the trial court lacks subject matter jurisdiction over the claims

asserted in John Curtis' s petition, and seeking dismissal of the entire suit with

prejudice. The LHSAA defendants also filed an exception of no cause of action

with regard to John Curtis' s claims for violation of its due process and equal

protection rights.

The factual basis for the LHSAA' s conclusion that a recruiting violation occurred was that an athlete was allowed to live with a John Curtis assistant football coach while the athlete attended John Curtis and participated on the varsity football team. John Curtis alleged that as a result of the LHSAA' s ruling that it committed a recruiting violation, John Curtis was forced to forfeit twenty football wins, including the 2013 LHSAA State Championship, and a monetary fine was imposed.

2 John Curtis filed a supplemental and amending petition, in which it alleged

that the trial court had subject matter jurisdiction over its tort claims because the

LHSAA breached its duty to govern or administer athletic events, in which its

members ( such as John Curtis) participate, in a reasonably prudent way. John

Curtis further alleged that the trial court had subject matter jurisdiction over

constitutional issues presented by this fact pattern to the extent that [ the

LHSAA' s] actions or inactions are in violation of Constitutional or statute

provisions."

Following the filing of John Curtis' s supplemental and amending petition,

the LHSAA defendants reurged their exceptions of lack of subject matter

jurisdiction and no cause of action and moved to have the exceptions set for

hearing. A hearing was held on the exceptions, as well as a motion for partial

summary judgment filed by John Curtis, on December 9, 2019. After taking the

matter under advisement, the trial court rendered a judgment on January 14, 2020,

noting that the " LHSAA is a private organization, not a public body, and ... there

is no jurisdiction to interfere with the internal proceedings of the LHSAA," and

further that " John Curtis' [ s] pleadings fail to set forth a due process claim under

color of state action or law, or any fundamental or express constitutional right,

state or federal, allegedly violated by LHSAA as the basis for a cause of action or

subject matter jurisdiction upon which this Court may grant relief." The trial court

sustained both exceptions and dismissed John Curtis' s suit with prejudice " for lack

ofjurisdiction and failure to state a cause of action." John Curtis appealed.

On appeal, John Curtis raised two assignments of error, both of which

concern the trial court' s conclusion that John Curtis failed to state a cause of

action. In its first assignment of error, John Curtis argued that the trial court erred

in sustaining the exceptions because John Curtis " state[ d] a cause of action based

on the arbitrary and capricious, bad faith conduct of the LHSAA that was ultra

3 vires under its own rules, and which fell below the standard of care for its

members." In its second assignment of error, John Curtis alleged that the trial

court erred in finding that it had " failed to state a cause of action against the

individual defendants, Eddie [ Bonine] and B. J. Guzzardo, Jr., for breach of their

fiduciary duties under the Louisiana Non -Profit Act and for defamation." John

Curtis failed to raise or brief any assignment of error with respect to the trial

court' s sustaining of the exception of lack of subject matter jurisdiction. Christian

Schools, Inc. v. Louisiana High School Athletic Association, 20- 0762, pp. 3- 4

La.App. 1 Cir. 2/ 19/ 21), 320 So.3d 1164, 1166, reh' g denied (Apr. 16, 2021).

Noting that this court only reviews issues raised on appeal, and further

noting that all assignments of error and issues for review must be briefed, this court

concluded that the propriety of the trial court' s ruling on the exception of lack of

subject matter jurisdiction was not properly before us. Furthermore, as a result of

John Curtis' s failure to seek reversal of the sustaining of the exception of lack of

subject matter jurisdiction, we concluded that its assignments of error concerning

the exception of no cause of action have been deprived of any legal significance

and are moot. For these reasons, we affirmed the judgment of the trial court.

Christian Schools, Inc., 20- 0762 at p. 5, 320 So. 3d at 1167. John Curtis filed an

application for a writ of certiorari, which was granted, and the supreme court

remanded the matter " with instructions to address whether the district court erred

in sustaining the defendants' ... exceptions of lack of subject matter jurisdiction

and no cause of action." Christian Schools, Inc. v. Louisiana High School Athletic

Association, 21- 00686 ( La. 10/ 05/ 21), 325 So. 3d 359 ( per curiam).

DISCUSSION

Subject Matter Jurisdiction

Subject matter jurisdiction is the legal power and authority of a court to hear

and determine a particular class of actions or proceedings, based upon the object of

M the demand, the amount in dispute, or the value of the right asserted. La. C. C. P.

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Christian Schools, Inc. d/b/a John Curtis Christian School v. Louisiana High School Athletic Association Eddie Bonine and B.J. Guzzardo, Jr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/christian-schools-inc-dba-john-curtis-christian-school-v-louisiana-lactapp-2022.