Eola Properties, LLC v. Bayou Jack Logging, LLC

CourtLouisiana Court of Appeal
DecidedOctober 1, 2014
DocketCA-0014-0362
StatusUnknown

This text of Eola Properties, LLC v. Bayou Jack Logging, LLC (Eola Properties, LLC v. Bayou Jack Logging, LLC) 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
Eola Properties, LLC v. Bayou Jack Logging, LLC, (La. Ct. App. 2014).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

14-362

EOLA PROPERTIES, L.L.C.

VERSUS

BAYOU JACK LOGGING, L.L.C., ET AL.

**********

APPEAL FROM THE TWELFTH JUDICIAL DISTRICT COURT PARISH OF AVOYELLES, NO. 2012-8424-A HONORABLE MARK A. JEANSONNE, DISTRICT JUDGE

MARC T. AMY JUDGE

Court composed of Ulysses Gene Thibodeaux, Chief Judge, Marc T. Amy, and Shannon J. Gremillion, Judges.

REVERSED IN PART. AFFIRMED IN PART.

Jerold Edward Knoll The Knoll Law Firm Post Office Box 426 Marksville, LA 71351 (318) 253-6200 COUNSEL FOR PLAINTIFF/APPELLEE: Eola Properties, L.L.C.

Joseph J. Valencino, III Burglass & Tankersley, L.L.C. 5213 Airline Drive Metairie, LA 70001-5602 (504) 836-0416 COUNSEL FOR DEFENDANTS/APPELLANTS: Kenneth Guillot Bayou Jack Logging, L.L.C. StarNet Insurance Company AMY, Judge.

The plaintiff entered into a stumpage contract for the removal of certain

timber on a 180-acre tract in which it owned a one-half interest. The plaintiff filed

this matter, seeking damages for timber trespass upon an allegation that the

defendant logger and his limited liability company impermissibly cut timber

beyond that designated in the contract. Following a jury trial and, upon entry of a

judgment notwithstanding the verdict, the trial court found in favor of the plaintiff,

awarding damages for the timber trespass and for loss of aesthetic value of the

affected land. The trial court also awarded attorney fees. The defendants appeal.

For the following reasons, we affirm in part and reverse in part.

Factual and Procedural Background

The plaintiff in this case, Eola Properties, L.L.C., owns an undivided one-

half interest in a 180-acre tract of timberland (Tract A) in Avoyelles Parish. The

plaintiff entered into a September 30, 2010 “Timber Stumpage Sales Contract”

with Bayou Jack Logging Company for the removal of certain hardwood on that

property. The contract indicated that Bayou Jack Logging Co. was represented

within that contract by Kenneth Guillot, its owner.

According to the record, Mr. Guillot began moving equipment to Tract A in

May of 2011. Thereafter, cutting was conducted June through August, 2011.

Pertinent to this timeline is Mr. Guillot’s formation of Bayou Jack Logging, L.L.C.

in June 2011.1 Subsequent to the logging operations, however, William M. Tebow,

a co-owner of and the land manager for Eola Properties, explained that he learned

from John Earles, a neighboring farmer and Eola Properties’ tenant, that there may

have been a timber trespass on adjacent tracts of land solely owned by Eola

Properties. Upon investigation, it was discovered that the Bayou Jack Logging 1 The record reflects a June 2, 2011 filing date with the Secretary of State. operations had been conducted not only upon the contracted lands in Tract A, but

also on a fifty-acre tract (Tract B), situated to the North of Tract A and on a

twenty-acre tract (Tract C), situated to the East of Tract A.

Eola Properties thereafter filed this matter against Mr. Guillot, Bayou Jack

Logging, L.L.C. and its insurer. Eola Properties sought damages for timber

trespass under La.R.S. 3:4278.1 2 and damages associated with the alleged

negligence leading to the trespass. The matter proceeded to trial, with the jury

returning a verdict on a verdict sheet divided into Section 1, entitled “Timber

Trespass” and Section 2, entitled “Negligence.”

With regard to the timber trespass claim brought under La.R.S. 3:4278.1, the

jury determined that “Bayou Jack Logging, LLC and/or its owner, Kenneth

Guillot” removed the timber without the consent of Eola Properties. The jury 2 Louisiana Revised Statutes 3:4278.1 was amended by 2011 La. Acts No. 226 during the timeline alleged in this case. In its present form, and in pertinent part, La.R.S. 3:4278.1(A) provides:

A. (1) It shall be unlawful for any person to cut, fell, destroy, remove, or to divert for sale or use, any trees, or to authorize or direct his agent or employee to cut, fell, destroy, remove, or to divert for sale or use, any trees, growing or lying on the land of another, without the consent of, or in accordance with the direction of, the owner or legal possessor, or in accordance with specific terms of a legal contract or agreement.

....

B. Whoever willfully and intentionally violates the provisions of Subsection A of this Section shall be liable to the owner, co-owner, co-heir, or legal possessor of the trees for civil damages in the amount of three times the fair market value of the trees cut, felled, destroyed, removed, or diverted, plus reasonable attorney fees and costs.

C. Whoever violates the provisions of Subsection A of this Section in good faith shall be liable to the owner, co-owner, co-heir, or legal possessor of the trees for three times the fair market value of the trees cut, felled, destroyed, removed, or diverted, if circumstances prove that the violator should have been aware that his actions were without the consent or direction of the owner, co- owner, co-heir, or legal possessor of the trees.

D. If a good faith violator of Subsection A of this Section fails to make payment under the requirements of this Section within thirty days after notification and demand by the owner, co-owner, co-heir, or legal possessor, the violator shall also be responsible for the reasonable attorney fees and costs of the owner, co-owner, co-heir, or legal possessor.

2 valued the subject timber at $23,941.89 and found that the defendants should have

been aware that the “actions were without consent or direction of Eola

Properties[.]” The jury further concluded that the defendants failed to make

payment within thirty days of notification and demand for the timber. See La.R.S.

3:4278.1(D). Thus, the jury assessed attorney fees against the defendants in the

amount of $3,986.33.

As for Eola Property’s claim in negligence, the jury determined that the

defendants were negligent in harvesting the trees on the fifty-acre and the twenty-

acre parcels and that the negligence was a legal cause of the claimed damages. The

jury assigned fifty percent of the fault to the defendants and fifty percent to Eola

Properties.3 The jury denied Eola Property’s claim for loss of aesthetic value and

the cost of clearing land.

In response to the motion of Eola Properties, the trial court entered a

judgment notwithstanding the verdict. In that judgment, and with regard to the

claim for trespass under La.R.S. 3:4278.1, the trial court: 1) increased the

determined fair market value of the felled timber from $23,941.89 to $47,883.71

and calculated the treble damages awardable pursuant to La.R.S. 3:4278.1(C) to be

$143,651.13; and 2) increased the award of attorney fees from $3,986.33 to

$40,000.00.

With regard to the jury’s verdict on Eola Property’s negligence claim, the

trial court entered a JNOV: 1) increasing the fault allocated to the defendants from

fifty percent to ninety percent and, correspondingly, decreasing the fault assessed

to Eola Properties from fifty percent to ten percent; and 2) awarding damages for

loss of aesthetic value in the amount of $35,000.00 and subjecting the award to a

3 The defendants alleged that Eola Properties was at fault in providing unreliable information regarding the location of its property lines. 3 ten percent reduction for the comparative fault assigned to Eola Properties. The

trial court maintained the judgment in all other respects.

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