Eros Pellerin v. Foster Farms, L.L.C.

CourtLouisiana Court of Appeal
DecidedJanuary 11, 2023
Docket54,829-CA
StatusPublished

This text of Eros Pellerin v. Foster Farms, L.L.C. (Eros Pellerin v. Foster Farms, L.L.C.) 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
Eros Pellerin v. Foster Farms, L.L.C., (La. Ct. App. 2023).

Opinion

Judgment rendered January 11, 2023. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 54,829-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

EROS PELLERIN Plaintiff-Appellant

versus

FOSTER FARMS, L.L.C., ET AL Defendants-Appellees

Appealed from the Third Judicial District Court for the Parish of Lincoln, Louisiana Trial Court No. 60,267

Honorable Monique B. Clement, Judge

PARKER ALEXANDER LLC Counsel for Appellant By: Chad C. Carter

HUDSON POTTS & BERNSTEIN, LLP Counsel for Appellees By: Gordon L. James Foster Farms, L.L.C. Donald H. Zeigler, III and Chris Shows

Before COX, HUNTER, and MARCOTTE, JJ. MARCOTTE, J.

This devolutive appeal arises from the Third Judicial District Court,

Lincoln Parish, Judge Monique B. Clement presiding. Eros Pellerin

(“plaintiff” or “appellant”) seeks review of the trial court’s judgment

granting summary judgment in favor of defendants, Foster Farms, L.L.C.

(“Foster Farms”) and Chris Shows (collectively, “defendants” or

“appellees”). The trial court found no genuine issue of material fact exists

making defendants liable for injuries plaintiff sustained after his car collided

with debris from a blown-out tire used on a trailer operated by Mr. Shows.

For the following reasons, we affirm the trial court’s ruling.

FACTS

On May 10, 2018, Mr. Shows was driving a tractor-trailer eastbound

on Interstate 20 hauling live chickens for Foster Farms. Plaintiff was also

driving his vehicle eastbound on Interstate 20 and was attempting to pass

Mr. Shows on the left. As plaintiff maneuvered to pass Mr. Shows, one of

the left rear tires on the trailer blew out, resulting in tire and other debris

striking plaintiff’s vehicle, causing plaintiff harm.

On March 8, 2019, plaintiff filed a petition against Mr. Shows and

Foster Farms seeking personal injury damages. Plaintiff claimed that the

accident was Mr. Shows’ fault, and that Mr. Shows was acting within the

course and scope of his employment with Foster Farms, rendering Mr.

Shows and Foster Farms jointly liable.

On April 8, 2019, defendants filed an answer to the petition wherein

they denied liability for the accident and asserted that the tire did not blow

out due to any fault on their part. Defendants maintained that the trailer and

tires were properly maintained and that the blowout occurred despite all reasonable efforts on their part. Defendants further asserted that “blowouts”

occur for a multitude of reasons beyond the control of the owner and driver,

including road debris, which cannot be reasonably detected when driving on

an interstate.

On October 24, 2019, defendants filed a motion for summary

judgment claiming that there was an absence of any factual support that

defendants knew, or in the exercise of reasonable care should have known,

of any issues with the tire that blew. Defendants pointed to the deposition

testimony of Mr. Shows wherein he testified that he inspected the tire in

question prior to leaving the yard with his truck. Mr. Shows testified that he

inspected the tire for cuts and damage as well as tread depth and separation.

He also used a “strike bar” to check the tire for air pressure. Mr. Shows

testified that nothing in his inspection revealed any issues with the tire.

Defendants further asserted that there was no evidence that any Foster

Farms employee should have known of any defect with the tire prior to the

incident. Defendants claimed that, to the contrary, the evidence showed that

Foster Farms and its employees exercised reasonable care through

numerous, meticulous, and regular inspections. Defendants claimed that the

inspection records they produced in discovery show the significant effort

Foster Farms undertook to inspect the trailer and its tires, including the

subject tire. Finally, defendants asserted that the inspection records indicate

that on the morning of the accident, the tires were checked and no problems

with them were noted. Whether plaintiff proceeds under a theory of general

negligence under Louisiana Civil Code article 2315 or strict liability under

Louisiana Civil Code article 2317.1, defendants claimed that the result is the

same since there are no facts which support plaintiff’s allegation that 2 defendant knew, or in the exercise of reasonable care should have known, of

defects in the tire that blew. Due to this lack of factual support, defendants

claimed that summary judgment was appropriate.

On October 13, 2021, plaintiff filed an opposition to defendants’

motion for summary judgment and a cross motion for partial summary

judgment. Plaintiff claimed that defendants were liable under a theory of

negligence per se due to alleged violations of various regulations and safety

rules relating to tire inspections and reports. Plaintiff claimed that

defendants did not properly inspect the trailer tires and failed to properly

report problems with the tires. Plaintiff also claimed that Foster Farms had

no way of knowing how many miles each live haul trailer tire had on it at

any given time. Plaintiff pointed out that certain rules, regulations, and

recommendations apply such as are found in the Federal Motor Carrier

Safety Regulations.

Specifically, plaintiff relied on 49 CFR §§ 396.3 and 396.11. 49 CFR

§ 396.3 prohibits a motor vehicle from being operated in a condition likely

to cause an accident or breakdown and holds that no commercial vehicle

may be driven unless the driver is satisfied that the vehicle’s parts and

accessories are in good working order. 49 CFR § 396.11 involves

requirements for the commercial driver’s post-trip inspection reports known

as the Driver Vehicle Inspection Report (“DVIR”). The DVIR must include

an inspection of the trailer as well as all defects in the parts and accessories

that were discovered by or reported to the driver during that day. Plaintiff

claimed that the DVIR had to contain all required information and signatures

and that these things were not properly adhered to. In addition, plaintiff

cited La. Admin. Code tit. 55, part III, § 813, which sets forth Louisiana’s 3 annual vehicle inspection procedures. Plaintiff claimed that defendants did

not comply with this provision of the Louisiana Administrative Code either.

Regarding the cause of the blowout, plaintiff claimed that the amount

of heat within the live haul trailer’s tires was to blame and that the amount of

heat in the tires was 100% controllable by Foster Farms had it used proper

maintenance and inspection procedures. Plaintiff argued that this claim is

supported by a statement made by Kelly Patrick, a mechanic employed by

Foster Farms. At Mr. Patrick’s deposition, he testified that the likely cause

of the accident was internal heat in the subject trailer tire.

Finally, plaintiff claimed that defendants failed to frequently and

accurately check the tire pressure in the tires of its live haul trailers and

failed to record what live haul trailer tires were replaced, when they were

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Eros Pellerin v. Foster Farms, L.L.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/eros-pellerin-v-foster-farms-llc-lactapp-2023.