Connie Couvillon and John M. Couvillon v. University Medical Center Management Corporation D/B/A Interim Lsu Public Hospital, Interim Lsu Public Hospital, and State of Louisiana, Board of Supervisors of Louisiana State University Agricultural and Mechanical College on Behalf of Lsu Health Science Center

CourtLouisiana Court of Appeal
DecidedNovember 2, 2023
Docket2023-CA-0076
StatusPublished

This text of Connie Couvillon and John M. Couvillon v. University Medical Center Management Corporation D/B/A Interim Lsu Public Hospital, Interim Lsu Public Hospital, and State of Louisiana, Board of Supervisors of Louisiana State University Agricultural and Mechanical College on Behalf of Lsu Health Science Center (Connie Couvillon and John M. Couvillon v. University Medical Center Management Corporation D/B/A Interim Lsu Public Hospital, Interim Lsu Public Hospital, and State of Louisiana, Board of Supervisors of Louisiana State University Agricultural and Mechanical College on Behalf of Lsu Health Science Center) 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.

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Connie Couvillon and John M. Couvillon v. University Medical Center Management Corporation D/B/A Interim Lsu Public Hospital, Interim Lsu Public Hospital, and State of Louisiana, Board of Supervisors of Louisiana State University Agricultural and Mechanical College on Behalf of Lsu Health Science Center, (La. Ct. App. 2023).

Opinion

CONNIE COUVILLON AND * NO. 2023-CA-0076 JOHN M. COUVILLON * VERSUS COURT OF APPEAL * UNIVERSITY MEDICAL FOURTH CIRCUIT CENTER MANAGEMENT * CORPORATION D/B/A STATE OF LOUISIANA INTERIM LSU PUBLIC ******* HOSPITAL, INTERIM LSU PUBLIC HOSPITAL, AND STATE OF LOUISIANA, BOARD OF SUPERVISORS OF LOUISIANA STATE UNIVERSITY AGRICULTURAL AND MECHANICAL COLLEGE ON BEHALF OF LSU HEALTH SCIENCE CENTER, ET AL.

APPEAL FROM CIVIL DISTRICT COURT, ORLEANS PARISH NO. 2019-06653, DIVISION “G-11” Honorable Robin M. Giarrusso, Judge ****** Chief Judge Terri F. Love ****** (Court composed of Chief Judge Terri F. Love, Judge Joy Cossich Lobrano, Judge Tiffany Gautier Chase)

LOBRANO, J., DISSENTS AND ASSIGNS REASONS

John W. Redmann Edward L. Moreno Kelly S. Rizzo LAW OFFICE OF JOHN W. REDMANN, LLC 1101 Westbank Expressway Gretna, LA 70053

COUNSEL FOR PLAINTIFFS/APPELLANTS John K. Nieset P. Ryan Plummer CHRISTOVICH & KEARNEY, LLP 2300 Pan American Life Center New Orleans, LA 70130-6078

COUNSEL FOR DEFENDANT/APPELLEE

AFFIRMED NOVEMBER 2, 2023 TFL This matter arises from a personal injury action involving the trial court’s TGC grant of summary judgment in favor of Defendant/Appellee TK Elevator

Corporation (“TKE”). Plaintiff Connie Couvillon filed a petition for damages

against LSU Medical Center (“UMC”) for injuries received as she entered its

parking garage elevator (“the elevator”).1 Thereafter, a supplemental petition was

filed against TKE in its capacity as the maintenance contractor for the elevator.

The petitions alleged that the trip and fall accident happened because the elevator

was uneven with the floor of the parking garage. Mrs. Couvillon’s husband and

adult children were substituted as party plaintiffs (“Appellants”) when she died

several months after the accident of unrelated causes.

TKE argued in its summary judgment motion that Appellants could not meet

the necessary elements to recover in negligence against TKE because the

undisputed facts showed that TKE performed adequate monthly maintenance on

the elevator; TKE had no notice of pre-accident or post-accident leveling problems

with the elevator; and TKE did not have to make any repairs as a result of the

1 UMC has four elevators in the parking structure, known as PS-A, PS-B, PS-C, and PS-D. UMC

identified the elevator involved in Mrs. Couvillon’s accident as PS-A. For purposes of this opinion, the PS-A elevator will be referenced as “the elevator.”

1 accident. On appeal, Appellants contend that the trial court erred in granting

summary judgment because genuine issues of fact and law remain as to whether

TKE breached its duty of care, TKE’s receipt of notice, and whether Appellants

were afforded adequate time to complete discovery.

Upon de novo review, we find that TKE met its duty of care in the

performance of its maintenance services under the contract with UMC; that TKE

did not receive notice of any un-leveling issues with the elevator prior to the fall;

and that Appellants had adequate time to complete discovery. Accordingly, the

judgment is affirmed.

FACTUAL AND PROCEDURAL HISTORY

On November 28, 2018, Mrs. Couvillon, her husband, and her grandson,

returned to the UMC parking garage elevators after she had completed an

appointment. As she entered the elevator, she fell forward. Mrs. Couvillon was

diagnosed with broken bones in both shoulders. Julia Nelson, UMC’s Public Safety

Officer, was called to the scene and took a report of the accident. The Couvillons

attributed the fall to a three-to-four inch misalignment between the parking garage

floor and the floor of the elevator.

Mrs. Couvillon initially filed suit against UMC on June 25, 2019. TKE was

added as a named defendant on May 14, 2021, after UMC’s discovery responses

revealed that it had a contract for elevator repair with TKE. TKE filed its motion

for summary judgment on October 18, 2022.

In support of the motion, TKE relied on the deposition testimonies of Brad

Groce,2 the TKE mechanic who serviced the elevator; Carey Becker, UMC’s

Assistant Vice President for Facilities and Support Services and its designated Art.

2 Mr. Groce was no longer employed by TKE at the time of his deposition.

2 1442 corporate representative;3 and Officer Nelson, UMC’s Public Safety Officer.

TKE also introduced the elevator’s Account History Report into evidence. TKE

maintained that Mr. Groce’s testimony conclusively established the following: (i)

TKE offered monthly maintenance service to the UMC elevators; (ii) Mr. Groce

had no personal recollection of any complaints or any calls to service the elevator

for any type of leveling problems before the incident; (iii) the elevator returned to

normal service without any repair work from TKE; and (iv) Mr. Groce verified that

the Account History Report did not show any “call-back” service calls for the

elevator for twelve months before the accident and six months thereafter for any

leveling issues involving the elevator.

TKE highlighted that UMC employees—Mr. Becker and Officer Nelson—

also testified that they had no knowledge of any leveling problems with the

elevator. Mr. Becker specifically testified that he had no recollection of any UMC

elevators requiring service because they were un-level. As to Officer Nelson, TKE

stressed that her testimony established that she did not personally observe that the

elevator was uneven with the floor of the parking garage on the accident date; she

had never seen the parking garage elevators open and be uneven with the floor in

the four or five years she had worked at the hospital; she had not previously

responded to a complaint where someone was injured by the elevator; and she

wrote in her notes that the elevator was uneven on the accident date only because

“that’s what they had said.” Accordingly, TKE argued that these depositions and

the Account History Report conclusively showed that it did not breach any duty of

care owed such that Appellants not only failed to establish an identifiable defect in

3 Mr. Becker testified that UMC’s Facilities Management Department encompasses its

Maintenance Department.

3 the elevator, but they also presented no proof that TKE had notice of a defect at

any time before the accident occurred.

Appellants countered that summary judgment was not appropriate based on

Mr. Couvillon’s deposition testimony that the elevator was defective because of

unevenness and the photographs of the elevator taken by the Couvillons’ son-in-

law on the accident date which allegedly depicted this unevenness.4 Appellants

also contended that TKE had not produced records generated by its software

programs—Intelligent Management Software (“IMS”) and TechConnect, discussed

infra. According to Appellants, these records arguably could dispute TKE’s claim

that it lacked notice of leveling defects. Appellants further maintained that they

needed additional discovery from UMC, in particular, the deposition of Jessica

Wright, the Service Center Assistant for UMC’s Maintenance Department, whose

job responsibilities entailed calling TKE to report elevator malfunction complaints.

In granting TKE’s summary judgment, the trial court emphasized that

Appellants failed to show that TKE had prior notice of any defect involving the

misalignment of the elevator. In response to Appellants’ claim that TKE had not

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Spott v. Otis Elevator Co.
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648 So. 2d 18 (Louisiana Court of Appeal, 1994)

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Connie Couvillon and John M. Couvillon v. University Medical Center Management Corporation D/B/A Interim Lsu Public Hospital, Interim Lsu Public Hospital, and State of Louisiana, Board of Supervisors of Louisiana State University Agricultural and Mechanical College on Behalf of Lsu Health Science Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/connie-couvillon-and-john-m-couvillon-v-university-medical-center-lactapp-2023.