Donsynia Riley Versus Acadian Companies

CourtLouisiana Court of Appeal
DecidedSeptember 3, 2025
Docket25-C-308
StatusUnknown

This text of Donsynia Riley Versus Acadian Companies (Donsynia Riley Versus Acadian Companies) 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
Donsynia Riley Versus Acadian Companies, (La. Ct. App. 2025).

Opinion

DONSYNIA RILEY NO. 25-C-308

VERSUS FIFTH CIRCUIT

ACADIAN COMPANIES, ET AL. COURT OF APPEAL

STATE OF LOUISIANA

ON APPLICATION FOR SUPERVISORY REVIEW FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT PARISH OF JEFFERSON, STATE OF LOUISIANA NO. 835-671, DIVISION "G" HONORABLE E. ADRIAN ADAMS, JUDGE PRESIDING

September 03, 2025

SUSAN M. CHEHARDY CHIEF JUDGE

Panel composed of Judges Susan M. Chehardy, Stephen J. Windhorst, and Timothy S. Marcel

WRIT DENIED SMC SJW TSM COUNSEL FOR DEFENDANT/RELATOR, ARCH SPECIALTY INSURANCE COMPANY Lorraine P. McInnis Jada C. Doucet

COUNSEL FOR PLAINTIFF/RESPONDENT, DONSYNIA RILEY Robert J. Caluda

COUNSEL FOR DEFENDANT/RESPONDENT, ACADIAN AMBULANCE SERVICE, INC., DANA SULLIVAN AND JUDSON SMYLY Parker W. Bradley CHEHARDY, C.J.

Relator/defendant, Arch Specialty Insurance Company, seeks review of the

trial court’s March 26, 2025 judgment denying its peremptory exception of no right

of action, and the trial court’s June 17, 2025 judgment denying Arch Specialty

Insurance Company’s motion for new trial. For the reasons that follow, finding no

error in the trial court’s judgments, we deny this writ application.

Factual Background and Procedural History

This litigation arises out of a petition for damages filed on December 6,

2022, by respondent/plaintiff, Donsynia Riley, and against defendants, Acadian

Companies d/b/a Acadian Ambulance Services, Inc., Dana Sullivan, and Judson

Smyly, (collectively “Acadian”), and XYZ Insurance Company, as the

“unidentified insurance company, at all relevant times hereto the liability insurance

carrier for the defendant Acadian Companies d/b/a Acadian Ambulance Service,

Inc. on the date of the accident.” In her petition, Mrs. Riley alleges that on

December 30, 2021, she was a guest at Ochsner Medical Center–Westbank

Hospital when she was struck/side-swiped by an empty stretcher, causing her

physical and mental injuries. Mrs. Riley avers that the stretcher was being

maneuvered down the hallway by defendants, Ms. Sullivan and Mr. Smyly, who

are employees of Acadian.

On November 6, 2024, nearly two years after filing her original petition,

Mrs. Riley filed a first supplemental and amending petition, seeking to substitute

the name of XYZ Insurance Company, as named in her original petition, with the

name of Arch Specialty Insurance Company (“Arch Specialty”), as the actual

liability carrier for Acadian.1 On January 24, 2025, Arch Specialty filed a

peremptory exception of no right of action alleging that Mrs. Riley does not have a

1 In her opposition to Arch Specialty’s writ application, Mrs. Riley contends that the reason defendants’ insurance company was named as XYZ Insurance Company in her original petition filed on December 6, 2022, was “because the Acadian defendants refused to disclose the identity of their liability insurer prior to litigation.” right to sue Arch Specialty based upon the liability insurance agreement with

Acadian’s employees, Ms. Sullivan and Mr. Smyly, and also does not have a right

of action to sue Arch Specialty directly under the Direct Action Statute, La. R.S.

22:1269, as amended.

Prior to the filing of Mrs. Riley’s first supplemental and amending petition,

the Louisiana legislature amended the Direct Action Statute, thereby removing a

plaintiff’s right of action to assert a direct action against a tortfeasor’s liability

insurance company. The amendment went into effect on August 1, 2024.

According to Arch Specialty, the amendment to the Direct Action Statute

eliminated Mrs. Riley’s right to assert a direct action against Arch Specialty,

Acadian’s liability insurer. Arch Specialty avers that the Direct Action Statute

merely grants a procedural right of action against an insurer where the plaintiff has

a substantive cause of action against the insured. In other words, Arch Specialty

avers that the legislative amendment to the Direct Action Statute, effective August

1, 2024, prohibits a plaintiff from pursuing a direct action against an insurer, unless

certain circumstances are met and/or established, which circumstances are not at

issue herein. Arch Specialty contends that because Mrs. Riley did not amend her

original petition to add or name it as a defendant until after the effective date of the

amendment, her right to assert a direct action against it as Acadian’s liability

insurer was not timely vested or invoked prior to the effective date of the

amendment, and therefore, the amendment to the Direct Action Statute should be

applied retroactively to this litigation. Consequently, Arch Specialty argues the

trial court erred when it failed to grant Arch Specialty’s exception of no cause of

action, and dismiss Mrs. Riley’s claims filed against it.

In response to Arch Specialty’s exception, Mrs. Riley argued that the Direct

Action Statute provides a substantive right, not procedural, and, therefore, the trial

court properly determined that the amendment does not apply retroactively.

2 Additionally, Mrs. Riley argued that at the moment she was injured in the accident

on December 30, 2021, she had a substantive right to bring a direct action under

the statute against Arch Specialty, which right was vested and timely invoked

when she filed her original petition on December 6, 2022, prior to the effective

date of the amendment. In support of her argument, Mrs. Riley urged the trial

court to rely on this Court’s decision in Riley v. Griffin, 24-537 (La. App. 5 Cir.

12/20/24), 410 So.3d 890, wherein we determined that “[w]hile an amendment to

the Direct Action Statute may apply retroactively to a cause of action that arose

before the amended statute’s August 1, 2024 effective date, this retroactivity stands

only in reference to causes of action for which suit had not yet been filed, and thus

the plaintiff’s right had not yet vested.” Id. at 895. According to Mrs. Riley, when

she filed her original petition on December 6, 2022, Acadian’s liability carrier was

named, although improperly identified as XYZ Insurance Company, but only

because the actual identity of Acadian’s liability insurer was unknown at that time.

She argued that it was not until after the effective date of the amendment to the

Direct Action Statute, through discovery, that Acadian divulged the identity of

Arch Specialty as its liability insurer, such that it could be properly substituted for

XYZ Insurance Company. Therefore, because she had invoked her right against

Acadian’s liability insurer by filing suit prior to the effective date of the

amendment to the statute, Mrs. Riley argued that she had a vested right directly

against Arch Specialty that cannot be divested by retroactively applying the

amended statute to her claim.

Arch Specialty’s exception came for hearing on February 26, 2025, at the

close of which, the trial court took the matter under advisement. On March 26,

2025, the trial court issued judgment in favor of Mrs. Riley, and against Arch

Specialty, overruling its exception of no right of action. The trial court issued

written reasons for judgment on April 11, 2025, finding that Arch Specialty had

3 “failed to meet the requisite burden and establish that the plaintiff, Mrs. Riley, does

not have a cause of action against it because Mrs. Riley’s right was vested on

December 30, 202[1] (date of incident) and it was timely invoked when she timely

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