Curtis Joseph Lawrence Versus Ashton Plantation Home Owners Association, Inc.

CourtLouisiana Court of Appeal
DecidedJune 28, 2022
Docket22-C-122
StatusUnknown

This text of Curtis Joseph Lawrence Versus Ashton Plantation Home Owners Association, Inc. (Curtis Joseph Lawrence Versus Ashton Plantation Home Owners Association, Inc.) 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
Curtis Joseph Lawrence Versus Ashton Plantation Home Owners Association, Inc., (La. Ct. App. 2022).

Opinion

CURTIS JOSEPH LAWRENCE NO. 22-C-122

VERSUS FIFTH CIRCUIT

ASHTON PLANTATION HOME OWNERS COURT OF APPEAL ASSOCIATION, INC. STATE OF LOUISIANA

ON APPLICATION FOR SUPERVISORY REVIEW FROM THE TWENTY-NINTH JUDICIAL DISTRICT COURT PARISH OF ST. CHARLES, STATE OF LOUISIANA NO. 86,580, DIVISION "E" HONORABLE TIMOTHY S. MARCEL, JUDGE PRESIDING

June 28, 2022

STEPHEN J. WINDHORST JUDGE

Panel composed of Judges Marc E. Johnson, Stephen J. Windhorst, and Hans J. Liljeberg

AFFIRMED SJW MEJ HJL COUNSEL FOR PLAINTIFF/RELATOR, CURTIS JOSEPH LAWRENCE Michael G. Bagneris John O. Pieksen, Jr.

COUNSEL FOR DEFENDANT/RESPONDENT, ASHTON PLANTATION HOME OWNERS ASSOCIATION, INC. Louis G. Authement WINDHORST, J.

Relator, Curtis Lawrence, seeks review of the trial court’s February 14, 2022

judgment (hereafter “the judgment”). Although the trial court was not sufficiently

convinced that relator contumaciously failed to comply with the mandates of the

prior consent judgment and did not hold him in contempt, the court found that relator

was nonetheless obligated to perform everything the consent judgment had ordered

and to which he had agreed, as well as damages to which he had agreed in the event

of non-performance. Accordingly, the trial court rendered judgment awarding

executory damages commensurate with those previously specified in the consent

judgment. For the reasons stated herein, we find no error in the trial court judgment.

Factual and Procedural Background

Respondent, Ashton Plantation Home Owners Association, Inc., filed a

petition and amended petition for permanent injunction against relator in 2019 and

2020 respectively. Trial was set on January 19, 2021. In lieu of a trial, the parties

reached a compromise (hereafter “the Stipulations”) whereby relator stipulated that

he violated the restrictions as alleged in the petitions, and relator was given an

additional six months to resolve the violations. The Stipulations further provided

that if relator did not resolve said violations, a trial was set for July 23, 2021. Relator

again failed to resolve said violations. On July 23, 2021, in lieu of the trial, the

parties entered into the consent judgment in which relator agreed to perform various

specified actions to resolve the violations, within specified deadlines, and agreed to

the imposition of daily penalties for the failure to comply, the same executed by the

trial court on July 26, 2022.

On November 8, 2021, respondent filed a pleading captioned “Rule for

Contempt,” seeking to: (1) have relator held in contempt for his failure to comply

with the terms of the consent judgment; (2) enforce the penalty provisions of the

consent judgment for failure to timely comply with the mandated actions; and

22-C-122 1 (3) for legal fees and expenses (hereafter cumulatively “the Rule”). The trial court

found relator was not in contempt, but enforced the penalty provisions of the consent

judgment. The February 14, 2022 judgment addresses respondent’s motion to

enforce consent judgment; calculates and orders the imposition of penalties against

relator and makes the penalties executory; and is silent as to the trial court’s ruling

on the issue of contempt.1

In his writ application, relator contends that (1) the trial court abused its

discretion by imposing monetary penalties against relator after finding that relator

was not in contempt of the July 23, 2021 consent judgment; (2) the trial court

erroneously relied on contract principles when imposing monetary penalties against

relator; and (3) the trial court erred by denying relator the use of the contract defense

theories to defend against the imposition of monetary penalties.

Relator incorrectly asserts that the only matter set before the trial court on

January 20, 2022 was the issue of contempt. Relator maintains that the trial court

did not have authority to rule in favor of respondent and impose monetary penalties

against relator after ruling that relator was not in contempt. Therefore, relator argues

that the trial court’s finding of no contempt is inconsistent with and precludes, the

imposition of any monetary penalties, so the judgment must be vacated or amended

to reflect the denial of respondent’s rule and removal of any award of monetary

penalties. Relator further argues that despite a finding that he was not in contempt,

the trial court “unilaterally, and without legal basis, inexplicably imposed what is

essentially a ‘strict liability’ standard to the consent judgment, and held that [relator]

was obligated to pay $38,700.00 in penalties to [respondent].” He claims that he did

1 Although the judgment is silent as to the trial court’s finding on the issue of contempt, the transcript shows

that the trial court specifically found that relator was not in contempt of the consent judgment. Regardless, when a judgment is silent as to a claim or demand that was litigated, it is deemed denied by the trial court. Cambre v. St. John the Baptist Parish, 12-590 (La. App. 5 Cir. 05/16/13), 119 So.3d 73, 81, writ denied, 13-1415 (La. 10/11/13), 123 So.3d 1227; Oreman v. Oreman, 07-296 (La. App. 5 Cir. 10/30/07), 971 So.2d 1149, 1158, writ denied, 08-128 (La. 03/12/08), 977 So.2d 919. Neither party has sought review of the trial court’s finding that relator was not in contempt.

22-C-122 2 not agree in the consent judgment to waive any contract defenses, such as Hurricane

Ida’s impact, force majeure, Act of God, and other bases for the impossibility of

performance. Thus, relator asserts if the trial court was correct in applying a breach-

of-contract analysis to the Rule, which he disputes, he should have been allowed to

present contractual defenses, including Hurricane Ida, to justify his inability to

perform the obligations required of him. Relator therefore argues that the trial

court’s use of a “strict liability” breach-of-contract analysis to impose penalties

against relator constitutes error as well.

In opposition, respondent contends that while captioned as “Rule for

Contempt,” respondent requested three separate and distinct forms of relief in the

prayer and in the rule to show cause order, specifically: (i) for relator to be found in

contempt of court; (ii) for relator to be cast in judgment for the daily penalties set

forth in the consent judgment; and (iii) for relator to be responsible for the costs and

attorneys’ fees incurred in the enforcement of the consent judgment. Respondent

argues that relator did not except or raise any objections, in writing or orally at the

hearing, to the scope of the proceeding or the forms of relief sought. Respondent

maintains that cumulation of the actions/relief requested in the Rule was permitted

under La. C.C.P. art 462 and La. C.C.P. art. 2592; therefore, any objection relator

may have was waived by relator and his counsel’s participation in the January 20,

2022 hearing. Respondent further asserts that the testimony and evidence supports

the relief requested in the Rule and the trial court did not err in imposing the daily

penalties set forth in consent judgment for relator’s noncompliance by the specific

deadlines to resolve the violations. Respondent contends that the trial court denied

its request to find relator in contempt, granted its request for imposition of penalties

set forth in the consent judgment, and preserved respondent’s right for costs and

attorneys’ fees.

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