Ginger Deforest v. Acadian Gardens Condominium Association

CourtLouisiana Court of Appeal
DecidedApril 28, 2023
Docket2022CA1157
StatusUnknown

This text of Ginger Deforest v. Acadian Gardens Condominium Association (Ginger Deforest v. Acadian Gardens Condominium Association) 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
Ginger Deforest v. Acadian Gardens Condominium Association, (La. Ct. App. 2023).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

NO. 2022 CA 1157

GINGER DEFOREST

VERSUS

ACADIAN GARDENS CONDOMINIUM ASSOCIATION

Judgment Rendered: APR 2 8 2023

Appealed from the 22nd Judicial District Court In and for the Parish of St. Tammany State of Louisiana Docket No. 2021- 13457

The Honorable Vincent J. Lobello, Judge Presiding

Ginger K. DeForest Plaintiff/Appellant Pro Se Covington, Louisiana

Stanley C. Kottemann, Jr. Counsel for Defendant/Appellee, Kenner, Louisiana Acadian Gardens Condominium Association

BEFORE: GUIDRY, C. J., WOLFE, AND MILLER, JJ. MILLER, J.

Ginger DeForest, plaintiff/appellant, appeals a judgment by the Twenty -

Second Judicial District Court sustaining a declinatory exception of improper

venue in favor of defendant/appellee, Acadian Gardens Condominium Association,

and dismissing Ginger DeForest' s petition with prejudice. For the following

reasons, we affirm in part, vacate in part, and remand with instructions.

FACTUAL AND PROCEDURAL HISTORY

On August 4, 2021, Ginger DeForest (" DeForest") filed a petition in the

Twenty -Second Judicial District Court (" district court") seeking to nullify a

judgment of the City Court for the City of Slidell (" city court")' and to have the

privilege reflecting the associated debt canceled. Acadian Gardens Condominium

Association (" Acadian") was named as the defendant. In her petition, DeForest

contended that her claim involved title to immovable property, that the city court

lacked subject matter jurisdiction to adjudicate the dispute, and therefore, that the

city court judgment was absolutely null under La. C.C.P. art. 2002. Thereafter, on

October 22, 2021, Acadian filed exceptions including: declinatory exceptions of lis

pendens, improper venue, and lack of subject matter jurisdiction; a dilatory

exception of vagueness or ambiguity of the petition; and peremptory exceptions of

prescription, peremption, res judicata, no right of action, and no cause of action.

At the hearing on the exceptions, the district court sustained Acadian' s

exception of improper venue and found that under La. C. C. P. art. 2006, a suit to

nullify a judgment must be brought in the court which rendered the judgment. The

district court further concluded that its ruling on the exception of improper venue

rendered Acadian' s other exceptions moot. The district court signed a judgment on

1 At the time this matter was heard in city court, the court was called City Court for the City of Slidell. The name subsequently changed to City Court of East St. Tammany. See La. R.S. 13: 2487. 1.

2 June 2, 2022, which sustained the exception of improper venue and dismissed

DeForest' s petition with prejudice. It is from this judgment that DeForest appeals.

ASSIGNMENTS OF ERROR

DeForest contends the district court erred in sustaining the exception of

improper venue; the district court erred in dismissing her petition with prejudice;

and the district court erred in executing the judgment prior to circulation under

Louisiana District Court Rule 9. 5.

DISCUSSION

First, DeForest contends the district court erred in sustaining Acadian' s

exception of improper venue. Venue is a question of law, which is reviewed de

novo by the appellate court. Alost v. Lawler, 2018- 1271 ( La, App. l' Cir. 5/ 8/ 19),

277 So. 3d 329, 334.

The nullity of a final judgment may be demanded for vices of either form or

substance. La. C. C. P. art. 2001. A vice of form renders the judgment an absolute

nullity. Leonard v. Reeves, 2011- 1009 ( La. App. 1st Cir. 1/ 12/ 12), 82 So. 3d 1250,

1259. A final judgment shall be annulled for vices of form if it is rendered against

an incompetent person not represented as required by law; or against a defendant

who has not been served with process as required by law and who has not waived

objection to jurisdiction, or against whom a valid default judgment has not been

taken; or by a court which does not have jurisdiction over the subject matter of the

suit. La. C. C. P. art. 2002( A).

An action of nullity is subject to the venue requirements of La. C.C.P. art.

2006, which provides that an action to annul a judgment must be brought in the

trial court, even though the judgment sought to be annulled may have been

affirmed on appeal, or even rendered by the appellate court. La. C.C.P. art. 2006;

Knight v. Sears Roebuck & Co., 89- 0947 ( La. App. l st Cir. 6/ 26190), 566 So. 2d

135, 137, writ denied, 90- 2141 ( La. 11130190), 571 So. 2d 628. The venue

3 established in La. C. C. P. art. 2006 is nonwaivable. La. C. C. P. art. 44. However, the

jurisprudence has developed an exception to the venue requirements of La. C. C. P.

art. 2006 when a person collaterally attacks an absolutely null judgment.2 Knight,

566 So. 2d at 137.

An action to annul a judgment for a vice of form may be brought by an

interested person at any time, before any court, and through a collateral attack. See

La. C.C.P. art. 2002( B) and Smithy. LeBlanc, 2006- 0041, p. 6 ( La. App. 1" Cir.

8115107), 966 So. 2d 66, 71. The venue exception has been consistently applied

only in suits where an absolutely null judgment is being collaterally attacked. This

court has found the venue exception should not be expanded to excuse the venue

requirements of La. C. C. P. art. 2006 when a party brings a direct action for the sole

purpose of annulling an absolutely null judgment. Knight, 566 So. 2d at 137.

DeForest' s petition to annul the city court judgment is not a collateral attack.

DeForest brought a direct action for the purpose of annulling the city court

judgment, and is thus beyond the scope of the jurisprudential exception to the

venue requirements of La. C. C. P. art. 2006. The district court did not err in

sustaining Acadian' s exception of improper venue. This assignment of error is

without merit.

Next, DeForest contends the district court erred in dismissing her petition

with prejudice. The district court, in deciding a declinatory exception of improper

venue, is afforded discretion in choosing to dismiss the action or transfer it to a

proper venue in the interest of justice. See La. C. C. P. arts. 121 and 932( B).

Appellate courts review this decision under the abuse of discretion standard of

2 A collateral attack is an attempt to impeach the judgment from one proceeding in another proceeding not instituted for the express purpose of annulling the judgment. Smith v. LeBlanc, 2006- 0041, p. 6 ( La. App. 1' t Cir. 8/ 15/ 07), 966 So. 2d 66, 71 n. 2. Such a collateral proceeding includes the assertion of the absolute nullity of a judgment as an affirmative defense, such as in an answer or by exception. Id., 966 So. 2d at 72.

4 review. Bertrand v. Desselle, 2022- 236 ( La. App. Yd Cir. 11/ 16/ 22), 353 So. 3d

936, 940.

The decision to transfer or dismiss a lawsuit due to improper venue is

addressed in La. C. C. P. arts. 121 and 932. Under Article 121, when an action is

brought in a court of improper venue, the court may dismiss the action, or in the

interest of justice transfer it to a court of proper venue. Similarly, under Article

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Related

Knight v. Sears, Roebuck & Co.
566 So. 2d 135 (Louisiana Court of Appeal, 1990)
In RE INTERDICTION OF DeMARCO
38 So. 3d 417 (Louisiana Court of Appeal, 2010)
Smith v. LeBlanc
966 So. 2d 66 (Louisiana Court of Appeal, 2007)
Leonard v. Reeves
82 So. 3d 1250 (Louisiana Court of Appeal, 2012)
In re Buhler
243 So. 3d 39 (Louisiana Court of Appeal, 2018)

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Ginger Deforest v. Acadian Gardens Condominium Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ginger-deforest-v-acadian-gardens-condominium-association-lactapp-2023.