David Briggs versus Junis Silas, Darrell Hunt and Progressive Insurance Company

CourtLouisiana Court of Appeal
DecidedNovember 15, 2023
Docket55,344-CA
StatusPublished

This text of David Briggs versus Junis Silas, Darrell Hunt and Progressive Insurance Company (David Briggs versus Junis Silas, Darrell Hunt and Progressive Insurance Company) 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
David Briggs versus Junis Silas, Darrell Hunt and Progressive Insurance Company, (La. Ct. App. 2023).

Opinion

Judgment rendered November 15, 2023. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 55,344-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

DAVID BRIGGS Plaintiff-Appellee

versus

JUNIS SILAS, DARRELL HUNT Defendants-Appellants AND PROGRESSIVE INSURANCE COMPANY

Appealed from the Monroe City Court for the Parish of Ouachita, Louisiana Trial Court No. 2021CV00066

Honorable Tammy Deon Lee, Judge

CASLER, BORDELON, Counsel for Appellants, LAWLER & GELDER Junis Silas and By: Jessica Crain Sanders Progressive Insurance Company

DAVID BRIGGS In Proper Person

Before STONE, COX, and THOMPSON, JJ. COX, J.

This civil appeal arises from Monroe City Court, Ouachita Parish,

Louisiana, regarding injuries and damages the plaintiff allegedly sustained

as a result of a motor vehicle accident. The trial court found the defendants

liable for the accident and awarded the plaintiff $10,250 in general damages,

and through an amended judgment, $7,542.49 in special damages. For the

reasons assigned below, the trial court’s judgment is reversed.

FACTS

On January 19, 2021,1 David Briggs (“Briggs”) filed a petition for

damages against Junis Silas (“Silas”) and Progressive Insurance Company

(collectively “Appellants”). In his petition, Briggs alleged to have sustained

personal injuries and damages to his vehicle, a 2006 Pontiac, following a

motor vehicle accident that occurred on January 16, 2020.

Briggs claimed he was traveling westbound on Louisville Avenue in

the right-hand lane when a 2014 Chevrolet Cruze owned by Darrell Hunt2

but operated by Silas, struck the rear of his vehicle. In response, Appellants

argued that moments before the accident, Briggs was in the left-hand lane

when he suddenly merged into the right-hand lane without warning, causing

Silas to collide with the back of Briggs’ vehicle.

On October 17, 2022, a bench trial was held wherein the following

testimony was adduced:

1 In the interest of thoroughness, this Court highlights that the date of injury occurred January 16, 2020, and Briggs filed suit for damages on January 19, 2021, more than one year from the date of the accident. See La. C.C. art. 3492. However, the issue was never addressed, and in accordance with La. C.C.P. art. 927, courts of appeal “shall not supply the objection of prescription” as it must be specifically pleaded. 2 Hunt was later dismissed from the suit. First, Briggs, proceedings pro se, testified that on the day of the

accident, he and his former girlfriend were en route to Ouachita Valley

Credit Union (“Credit Union”) on Louisville Avenue, traveling westbound

in the right-hand lane. Briggs explained that when the car in front of him

stopped, he slowed down, and Silas’ vehicle collided into the back of his

Pontiac. Briggs testified that shortly after the accident, he was transported to

Elite Healthcare Alliance (“Elite Healthcare”)3 where he finally spoke with

Officer Timothy Stevens (“Officer Stevens”). Briggs stated that Officer

Stevens, without taking either his or his former girlfriend’s statements, made

negative assumptions about his character, determined he was the liable party

for the accident, and then issued him a citation.

Briggs testified that shortly after the citation was issued, nurses ceased

treatment, he was abruptly discharged, and he was later unable to receive

any form of chiropractic treatment to address the injuries to his back and leg.

Briggs then informed the trial court he brought copies of his medical records

as evidence of his injuries and treatments he received; however, no

documents were introduced during trial.

In addressing damages to his vehicle, Briggs testified the back bumper

was torn off and “the backside of the wheel, you couldn’t hardly drive like a

trunk like, you know, you just had to leave it alone until it could be fixed.”

Briggs stated that because of the outstanding ticket, he could not receive an

estimate for damages or have the vehicle fixed. Briggs testified that his

vehicle remained inoperable for two years which forced him to leave it in the

3 Based on the evidence provided in the record, it appears that Briggs was first transported to Ochsner LSU Health, and then he personally sought treatment with Elite Healthcare. 2 parking lot of his apartment complex before his landlord had the vehicle

towed.

On cross-examination, counsel for Appellants introduced copies of

Briggs’ medical records regarding treatment he received prior to the

accident, including treatment for vision loss in his right eye as well as forms

where Briggs indicated he smoked marijuana every other day. In response,

Briggs generally denied receiving treatment for his eye or that he ever

smoked marijuana. Briggs then admitted that in the two years since the

accident, he never took pictures of the damages to his vehicle. Briggs then

reiterated he was unable to receive an estimate for damages or have repairs

done because of the outstanding citation.

Counsel for the Appellants then introduced copies of Briggs’ medical

records following the accident, highlighting Briggs voluntarily discharged

himself as staff notes indicated that Briggs “. . . got upset and said that he

was going to St. Francis. [Briggs] snapped and started cursing the staff and

wanted his paperwork.” Briggs denied that he voluntarily left the hospital

and insisted staff refused to treat him after Officer Stevens issued the

citation. Finally, counsel introduced copies of traffic citations Briggs

received after the accident involving the same 2006 Pontiac involved in the

present case. Counsel noted the dates of the citations as October 24, 2020;

December 7, 2020; and June 26, 2021. Briggs then denied receiving any

traffic citations following the accident.

Next, Officer Stevens reviewed his crash report and testified that on

January 16, 2020, at approximately 11:29 a.m., he was dispatched to

Louisville Avenue regarding a motor vehicle accident. Officer Stevens

noted the roads were wet that day. He then explained that in the normal 3 course of his investigations he speaks with and checks on the conditions of

all parties involved and records their statements for his report. Officer

Stevens stated that in this case, he spoke with Brenda Bryant (“Bryant”), an

independent witness, and Silas at the scene of the accident. He recalled that

both Bryant and Silas generally reported that Briggs was in the left-hand

lane before he suddenly merged into the right-hand lane, causing Silas to

rear-end the back of Briggs’ vehicle.

Officer Stevens admitted he could not remember whether he spoke

with Briggs at the scene, but stated he did take Briggs’ statement at the

hospital. Officer Stevens testified that Briggs reported that he was in the

right-hand lane and that as he slowed down, Silas hit the back of his vehicle.

Officer Stevens stated that after he recorded Briggs’ statement, he

determined Briggs was at fault for the accident and issued a citation for

improper lane use. Officer Stevens explained that after Briggs refused to

sign the citation, he explained to Briggs that he could potentially face a fine

for failure to do so. Officer Stevens then generally denied making

assumptions about Brigg’s character.

Next, Bryant testified that on the day of the accident, she was

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David Briggs versus Junis Silas, Darrell Hunt and Progressive Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/david-briggs-versus-junis-silas-darrell-hunt-and-progressive-insurance-lactapp-2023.