Dyraneshia Warren, Individually and as the Legal Heir of Chalanta Brown and Bobbie Franklin Jr, Individually and as the Legal Heir of Chalanta Brown Versus Hdi Global Insurance Company; Gaubert Oil Company Inc.; Grady Gaubert; Glenn Robichaux Jr. and State of Louisiana, Through Department of Public Safety and Corrections, Louisiana State Police

CourtLouisiana Court of Appeal
DecidedMay 16, 2022
Docket21-CA-570
StatusUnknown

This text of Dyraneshia Warren, Individually and as the Legal Heir of Chalanta Brown and Bobbie Franklin Jr, Individually and as the Legal Heir of Chalanta Brown Versus Hdi Global Insurance Company; Gaubert Oil Company Inc.; Grady Gaubert; Glenn Robichaux Jr. and State of Louisiana, Through Department of Public Safety and Corrections, Louisiana State Police (Dyraneshia Warren, Individually and as the Legal Heir of Chalanta Brown and Bobbie Franklin Jr, Individually and as the Legal Heir of Chalanta Brown Versus Hdi Global Insurance Company; Gaubert Oil Company Inc.; Grady Gaubert; Glenn Robichaux Jr. and State of Louisiana, Through Department of Public Safety and Corrections, Louisiana State Police) 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
Dyraneshia Warren, Individually and as the Legal Heir of Chalanta Brown and Bobbie Franklin Jr, Individually and as the Legal Heir of Chalanta Brown Versus Hdi Global Insurance Company; Gaubert Oil Company Inc.; Grady Gaubert; Glenn Robichaux Jr. and State of Louisiana, Through Department of Public Safety and Corrections, Louisiana State Police, (La. Ct. App. 2022).

Opinion

DYRANESHIA WARREN, ET AL NO. 21-CA-570

VERSUS FIFTH CIRCUIT

HDI GLOBAL INSURANCE COMPANY; ET COURT OF APPEAL AL STATE OF LOUISIANA

ON APPEAL FROM THE TWENTY-NINTH JUDICIAL DISTRICT COURT PARISH OF ST. CHARLES, STATE OF LOUISIANA NO. 84,455, DIVISION "E" HONORABLE TIMOTHY S. MARCEL, JUDGE PRESIDING

May 16, 2022

HANS J. LILJEBERG JUDGE

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

AFFIRMED IN PART; REVERSED IN PART; REMANDED HJL MEJ SJW COUNSEL FOR PLAINTIFF/APPELLANT, DYRANESHIA WARREN ET AL. Thomas D. Bowers, III Monique N. Green

COUNSEL FOR DEFENDANT/APPELLEE, STATE OF LOUISIANA, THROUGH THE DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS, LOUISIANA STATE POLICE Jeffrey M. Landry Amber M. Babin Wm. David Coffey Thomas M. Brahney LILJEBERG, J.

Plaintiffs appeal the trial court’s judgment which granted the exceptions of

no right of action filed by defendant and dismissed plaintiffs’ claims against it. For

the following reasons, we affirm in part, on other grounds, and reverse in part.

FACTS AND PROCEDURAL HISTORY

This case arises from a motor vehicle accident that occurred on April 13,

2017. The petition alleges that Chalanta Brown was driving a dump truck owned

by her employer, KASS Bothers, Inc., on Interstate 310 in St. Charles Parish,

Louisiana, when she was struck from behind by a tanker truck and trailer owned by

Gaubert Oil Company, Inc. and driven by Glenn Robichaux. Plaintiffs assert that

the tanker truck contained 8,500 gallons of gasoline that spilled during the collision

and caused a large fire. Plaintiffs further state that the dump truck flipped onto its

side upon impact, trapping Ms. Brown inside and causing her to burn to death.

On April 10, 2018, Ms. Brown’s children, Dyraneshia Warren and Bobbie

Franklin, Jr., individually and as the legal heirs of Ms. Brown, filed this lawsuit

against several defendants, including the State of Louisiana, through the

Department of Public Safety and Corrections, Louisiana State Police (“LSP”). In

their petition, plaintiffs alleged that the LSP, through the acts or omissions of its

investigating troopers, failed to perform adequate drug and alcohol testing to

determine if Mr. Robichaux was intoxicated at the time of the accident. They

asserted that Louisiana law requires blood sampling for alcohol and illegal drugs

when a motor vehicle accident results in a fatality, but the investigating troopers

“consciously chose to disregard the statutory obligations of these statutes and knew

to a substantial certainty that said failure to follow procedures would impair later

proof of intoxication.” They asserted that the LSP is vicariously liable for the

damages caused by the troopers’ failure to follow specific procedures, and for

21-CA-570 1 intentional spoliation of evidence or, alternatively, negligent spoliation of

evidence.

On August 18, 2020, the LSP filed peremptory exceptions of no cause of

action and no right of action. It asserted that Louisiana law does not recognize a

cause of action for negligent spoliation and that plaintiffs have failed to allege any

operative facts that would warrant maintaining a cause of action for intentional

spoliation or failure to carry out a statutory duty. The LSP also argued that

plaintiffs have no right of action against the LSP for failure to carry out a statutory

duty, because the LSP owes no private duty under La. R.S. 32:681 to individuals in

the investigation of an accident.

Plaintiffs filed a memorandum in opposition to the LSP’s exceptions, in

which they conceded that the exception of no cause of action as to negligent

spoliation should be granted, but argued that they had stated valid causes of action

for both intentional spoliation of evidence and failure to carry out a statutory duty.

Plaintiffs further asserted that as the children and legal heirs of Ms. Brown, they

have a right of action against the LSP for intentional spoliation of evidence and

failure to carry out a statutory duty.

The LSP’s peremptory exceptions of no cause of action and no right of

action came for hearing before the trial court via Zoom on January 26, 2021. After

considering the arguments of counsel, the trial court granted the LSP’s exceptions

of no cause of action for negligent spoliation of evidence, no right of action for

intentional spoliation of evidence, and no right of action for failure to fulfill a

statutory duty. The trial court signed a written judgment on February 24, 2021,

dismissing all of plaintiffs’ claims against the LSP with prejudice. Plaintiffs

appeal.

21-CA-570 2 LAW AND DISCUSSION

On appeal, plaintiffs argue that the trial court erred by granting the LSP’s

exceptions of no cause of action as to their claims of intentional spoliation of

evidence and failure to carry out a statutory duty. They contend that the petition

adequately states a cause of action for each claim, but if the trial court found it

deficient, it should have allowed them the opportunity to amend the petition.

Plaintiffs also argue that the trial court erred by granting the exceptions of no right

of action.

The record reflects that the trial court did not grant the LSP’s exceptions of

no cause of action as to intentional spoliation of evidence and failure to fulfill a

statutory duty. Rather, the trial court granted the LSP’s exceptions of no right of

action as to these claims. The exceptions of no cause of action and no right of

action are often confused or improperly combined, yet they are separate and

distinct. Badeaux v. Southwest Computer Bureau, Inc., 05-612 (La. 3/17/06), 929

So.2d 1211, 1216. An exception of no cause of action raises a question of whether

the law affords a remedy to anyone under the factual allegations of the petition,

while an exception of no right of action raises the issue of whether the plaintiff

belongs to the particular class to which the law grants a remedy for the particular

harm alleged. Id.; Zar v. Gaudet, 94-533 (La. App. 5 Cir. 12/14/94), 648 So.2d

1012, 1013. Appellate courts review rulings on exceptions of no cause of action

and no right of action de novo. Industrial Companies, Inc. v. Durbin, 02-0665 (La.

1/28/03), 837 So. 2d 1207, 1215.

The LSP raised both exceptions of no right and no cause of action in the trial

court.1 Although exceptions of no cause of action and no right of action each serve

a particular purpose with different procedural rules, when there is no cause of

1 We note that this Court may also raise and consider these exceptions sua sponte. See La. C.C.P. art. 927(B); Bayou Fleet Partnership v. Clulee, 13-934 (La. App. 5 Cir. 9/10/14), 150 So.3d 329, 333.

21-CA-570 3 action, there can be no right of action. Girtley v. ACE American Ins. Co., 15-397

(La. App. 5 Cir. 12/9/15), 182 So.3d 351, 357. We will first address whether the

petition states a cause of action for intentional spoliation of evidence or failure to

carry out a statutory duty.

A cause of action, for purposes of the peremptory exception, is defined as

the operative facts that give rise to the plaintiff's right to judicially assert the action

against the defendant. DiLeo v. Hansen, 09-974 (La. App. 5 Cir. 6/29/10), 45

So.3d 1120, 1122-23. The function of the exception of no cause of action is to test

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Dyraneshia Warren, Individually and as the Legal Heir of Chalanta Brown and Bobbie Franklin Jr, Individually and as the Legal Heir of Chalanta Brown Versus Hdi Global Insurance Company; Gaubert Oil Company Inc.; Grady Gaubert; Glenn Robichaux Jr. and State of Louisiana, Through Department of Public Safety and Corrections, Louisiana State Police, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dyraneshia-warren-individually-and-as-the-legal-heir-of-chalanta-brown-and-lactapp-2022.