Deanna Smith v. State of Louisiana Through the Department of Transportation and Development

CourtLouisiana Court of Appeal
DecidedMarch 2, 2022
DocketCA-0021-0192
StatusUnknown

This text of Deanna Smith v. State of Louisiana Through the Department of Transportation and Development (Deanna Smith v. State of Louisiana Through the Department of Transportation and Development) 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
Deanna Smith v. State of Louisiana Through the Department of Transportation and Development, (La. Ct. App. 2022).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

21-192

DEANNA SMITH

VERSUS

STATE OF LOUISIANA THROUGH THE DEPARTMENT OF TRANSPORTATION AND DEVELOPMENT, J. B. JAMES CONSTRUCTION, LLC, AND FOUKE SAND & GRAVEL, LLC,

********** ON APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. 2018-5856 HONORABLE MICHELLE M. BREAUX, DISTRICT JUDGE

********** JONATHAN W. PERRY JUDGE

**********

Court composed of Sylvia R. Cooks, Chief Judge, Jonathan W. Perry and Charles G. Fitzgerald, Judges.

Cooks, Chief Judge, dissents and assigns written reasons.

AFFIRMED. Carl J. Rachal Bart Bernard Bart Bernard Injury Lawyers 1031 Camellia Blvd. Lafayette, LA 70508 (337) 989-2278 COUNSEL FOR PLAINTIFF/APPELLANT: Deanna Smith

Thomas G. Buck Brett W. Tweedel Blue Williams, L.L.P. 3421 N. Causeway Blvd., St. 900 Metairie, LA 70002 (504) 831-4091 COUNSEL FOR DEFENDANTS/APPELLEES: J. B. James Construction, LLC and Fouke Sand & Gravel, LLC

Matthew C. Nodier David C. Bolton Nodier Law Firm 8221 Goodwood Blvd., Ste. A Baton Rouge, LA 70806 (225) 448-2267 COUNSEL FOR DEFENDANT/APPELLEE: State of Louisiana, Department of Transportation and Development PERRY, Judge.

Deanna Smith (“Smith”) appeals the trial court’s judgment that dismissed her

personal injury lawsuit against JB James Construction, LLC (“JB James”) and Fouke

Sand & Gravel, LLC (“Fouke”) (collectively “Defendants”), on a motion for

summary judgment. We affirm.

FACTS AND PROCEDURAL HISTORY

The facts of this case center on Smith’s trip and fall on November 20, 2017,

at the intersection of Verot School Road and Camellia Boulevard/Artisan Road (“the

intersection”) in Lafayette. At the time of Smith’s accident, the intersection where

Smith fell was part of a major construction site to improve Verot School Road.

The Louisiana Department of Transportation and Development (“LADOTD”)

had contracted with JB James to perform the construction work. LADOTD prepared

the plans and specifications for the work. Included in the plans and specifications

were the location for all signs, barricades, and cones that JB James was required to

install; the plans and specifications included specific signage at the intersection.

There was a sign on Artisan, alerting individuals that there was construction ahead

and signs, barricades, and cones were in the intersection, including a “road closed”

sign attached to a barricade.

Smith admitted that she was aware of the construction site at the intersection

and that it had been under construction for some time. On the date of the accident,

Smith, accompanied by her golden retriever, approached the intersection. As she

walked across the intersection at a brisk pace, her foot caught on taut string1 strewn

across a portion of the roadway construction, causing her to trip and fall. As a result

1 In the petition for damages, Smith references that the cause of her fall was “an ankle high cable across the roadway and/or sidewalk and adjacent roadside[.]” At various places in her deposition, Smith referred to it variously as a wire or as high tensile fishing line. In yet another part of her deposition, Smith identified the cable/line as being yellow and affixed to a traffic signal pole. Now, in her brief to this court, Smith says that she fell when she encountered a string. For consistency we will refer to the obstacle as a string. of her fall to the concrete roadway, Smith injured her right elbow and underwent two

corrective surgeries to address those injuries.

Smith filed a petition for damages on September 21, 2018, naming LADOTD

as defendant.2 On November 19, 2018, Smith filed an amending and supplemental

petition, naming JB James, Fouke, Ernest P. Breaux Electrical, LLC (“Ernest P.

Breaux”), and the Lafayette City-Parish Consolidated Government (“LCPG”) as

additional defendants. Smith’s claims against LCPG were dismissed without

prejudice on March 27, 2019, and her claims against Ernest P. Breaux were

dismissed on September 10, 2019, with prejudice.3

On June 2, 2020, Defendants filed a motion for summary judgment, seeking

the dismissal of Smith’s claims against them because the alleged defect was open

and obvious, and they were entitled to immunity under La.R.S. 9:2771. After Smith

filed her opposition to the motion for summary judgment, the trial court heard oral

argument. After considering the pleadings, evidence, and oral argument, the trial

court granted Defendants’ motion for summary judgment.4

Smith appealed urging two assignments of error:

(1) Whether JB James and Fouke were entitled to summary judgment on the grounds that the defect was open and obvious where Plaintiff testified, she never saw the string running across the road before she fell, and photographs show the string was difficult to see.

(2) Whether JB James and Fouke were entitled to immunity under Louisiana Revised Statutes § 9:2771 where evidence indicated a thin, hard to see string was running across a pedestrian walkway.

2 Although LADOTD is a defendant in this litigation, it is not involved in this appeal. 3 Breaux and LCPG are not involved in this appeal.

4 The trial court did not state on what grounds it granted the Defendants’ motion for summary judgment. Because we find the Defendants were entitled to summary judgment on the grounds that the defect was open and obvious, we will not discuss whether the Defendants were also entitled to immunity under La.R.S. 9:2771. 2 LAW AND DISCUSSION

Appellate Practice

From the outset, Defendants urge us to disregard Smith’s arguments because

her brief does not reference specific page numbers of the record in support of her

arguments and further fails to include a concise statement of the applicable standard

of review for each assignment of error and issue for review. Smith has not responded

to these asserted deficiencies.5

Uniform Rule—Courts of Appeal, Rule 2-12.4A(9)(a) and (b) states:

The brief of the appellant shall contain, under appropriate headings and in the order indicated:

....

9. the argument, which shall contain:

(a) appellant’s contentions, with reference to the specific page numbers of the record and citations to the authorities on which the appellant relies,

(b) for each assignment of error and issue for review, a concise statement of the applicable standard of review, which may appear in the discussion or under a separate heading placed before the discussion[.]

Uniform Rules—Courts of Appeal Rule 2-12.13 states that “[b]riefs not in

compliance with these Rules may be stricken in whole or in part by the court, and

the delinquent party or counsel of record may be ordered to file a new or amended

brief.” Thus, the appellate court has the discretion to impose a sanction for

noncompliance with the Uniform Rules. The Louisiana Supreme Court in U.S. Fire

Ins. Co. v. Swann, 424 So.2d 240, 244-45 (La.1982), (citations omitted) explained:

5 “The appellant may file a reply brief, if he has timely filed an original brief, but it shall be strictly confined to rebuttal of points urged in the appellee’s brief.” Uniform Rules—Courts of Appeal, Rule 2-12.6. Even after these omissions were brought to light, counsel for the appellant has failed to respectfully provide this court with a reply brief to remedy these deficiencies. “Lawyers who advocate the claims and causes of their clients before courts and other tribunals should be zealous advocates for their clients.” Frank L. Maraist, N. Gregory Smith, Thomas C. Galligan, Jr., 21 La. Civ. L.

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