In Re: Succession of Donald Clay Smith

CourtLouisiana Court of Appeal
DecidedFebruary 3, 2010
DocketCA-0009-0969
StatusUnknown

This text of In Re: Succession of Donald Clay Smith (In Re: Succession of Donald Clay Smith) 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
In Re: Succession of Donald Clay Smith, (La. Ct. App. 2010).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

09-969

IN RE: SUCCESSION OF DONALD CLAY SMITH

**********

APPEAL FROM THE TWENTY-EIGHTH JUDICIAL DISTRICT COURT PARISH OF LASALLE, NO. 35,828 HONORABLE J. CHRISTOPHER PETERS, DISTRICT JUDGE

ULYSSES GENE THIBODEAUX CHIEF JUDGE

Court composed of Ulysses Gene Thibodeaux, Chief Judge, John D. Saunders, and James T. Genovese, Judges.

Genovese, J., concurs in the result.

AFFIRMED.

Walter Evans Dorroh, Jr. P. O. Box 1889 Jena, LA 71342 Telephone: (318) 992-4107 COUNSEL FOR: Appellees- Angela Smith Appleby and Winnie Moore Smith

James L. Carroll P. O. Box 1619 Columbia, LA 71418 Telephone: (318) 649-9284 COUNSEL FOR: Appellant - Clayton Donnell Barnhill THIBODEAUX, Chief Judge.

Appellant, Clayton Donnell Barnhill, an alleged biological child of the

deceased, Donald Clay Smith, claims that the trial court erred by sustaining Winnie

Moore Smith and Angela Smith Appleby’s exception of prescription. Barnhill

maintains that the trial court erroneously interpreted the 2005 Civil Code amendment

that governs filiation actions.1 Reasoning that the amendment did not apply

retroactively so as to revive expired and extinguished filiation claims, the trial court

dismissed with prejudice Barnhill’s petition to amend the judgment of possession in

favor of Smith and Appleby. For the following reasons, we affirm.

I.

ISSUE

We shall consider whether the 2005 Civil Code amendment governing

filiation actions allowed a child, born outside of marriage, to bring a filiation action

in 2008 and thereby claim a portion of the intestate deceased’s estate where (1) the

child became twenty years of age in 1998, and (2) the deceased died in 2007.

II.

FACTS

Barnhill, born May 28, 1978, claims to be a biological child of the

deceased and Eunice Cruse Barnhill. At the time of Barnhill’s birth, the deceased

was married to Winnie Moore Smith, and Eunice Cruse Barnhill was married to

Johnny Barnhill. The deceased never acknowledged Barnhill as his child. Barnhill

never attempted to filiate to the deceased until this suit.

After the deceased’s death in 2007, his surviving spouse, Smith, and his

surviving child born of this marriage, Angela Smith Appleby, filed a petition for

1 2005 La. Acts No. 192, vacating La.Civ.Code art. 209 and adding La.Civ.Code art. 197. possession. The trial court issued a judgment of possession recognizing Smith as the

surviving spouse in community of the deceased and granting her a legal usufruct over

the undivided one-half interest of the deceased’s and all of the community property.

The trial court also recognized Appleby as the only heir of the deceased and placed

her in possession as the owner of all the deceased’s property, subject to her mother’s

usufruct.

Barnhill filed a petition to amend the judgment of possession and to

establish paternity. Alleging that he is a biological son of the deceased, Barnhill

requested disinterment of the deceased to collect his DNA for paternity testing. He

further demanded, as a biological child of the deceased, ownership of a one-half

interest in all of the deceased’s property.

Smith and Appleby filed an exception of prescription and peremption.

They asserted that at the time Barnhill passed the age of nineteen, he lost the right to

filiate under the law in effect at that time. Thus, they alleged that because Barnhill

could not establish paternity, he had no claim to the deceased’s estate. Agreeing with

Smith and Appleby, the trial court sustained their exception.

Barnhill appeals claiming that, based on the 2005 amendment to the

Civil Code, the applicable peremptive period is one year from the day of the death of

the alleged father, irrespective of the child’s age. Barnhill argues this peremptive

period applies because the deceased died after the amendment became effective.

III.

STANDARD OF REVIEW

Appellate courts review for manifest error judgments on the exception

of prescription. Credeur v. Champion Homes of Boaz, Inc., 08-1096 (La.App. 3 Cir.

3/4/09), 6 So.3d 339, writ denied, 09-1099 (La. 9/4/09), 17 So.3d 965. On the other

2 hand, courts review statutory interpretations de novo because they present questions

of law. Stewart v. Estate of Stewart, 07-333 (La.App. 3 Cir. 10/3/07), 966 So.2d

1241.

IV.

LAW AND DISCUSSION

The now-vacated La.Civ.Code art. 209 required a child not entitled to

legitimate filiation to institute filiation proceedings “within one year of the death of

the alleged parent or within nineteen years of the child’s birth, whichever first

occurs.” Our legislature substantively changed this law by the Filiation of Parents

and Children Act, effective June 29, 2005, No. 192, 2005 La. Acts 1444. The

legislature made changes expressed in that Act “applicable to all claims existing or

actions pending on its effective date and all claims arising or actions filed on and after

its effective date.” 2005 La. Acts No. 192, § 3 (emphasis added).

The current law reads that “for purposes of succession only,” the

peremptive period for a child to “institute an action to prove paternity[,] even though

he is presumed to be the child of another man[,]” is one year “from the day of the

death of the alleged father.” La.Civ.Code art. 197. Thus, under the prior law, the

child’s age was extremely important. The current law, on the other hand, requires the

child to bring the suit within one year of the parent’s death irrespective of the child’s

age. Because the alleged heir in this case reached the age of nineteen in 1997, at the

time the now-vacated La.Civ.Code art. 209 was in effect, the question is whether the

2005 amendment applies retroactively to revive this already-perempted filiation

action.

This and other Louisiana courts have already examined the 2005

amendment’s effect. Thus, where the alleged father died prior to the amendment, but

3 the children’s appeal was pending when the amendment became effective, this court

rejected the amendment’s applicability to the filiation actions of the alleged heirs who

were well beyond nineteen years of age. In re Succession of McKay, 05-603 (La.App.

3 Cir. 2/1/06), 921 So.2d 1219, writs denied, 06-504, 06-631 (La. 6/2/06), 929 So.2d

1252, 1253. This court explained that although, generally, prescriptive statutes are

procedural, once the prescriptive period elapses, a party acquires a right to plead the

exception of prescription. Id. (quoting Chance v. Am. Honda Motor Co., Inc., 93-

2582 p. 2 (La. 4/11/94), 635 So.2d 177, 178). A change in the right to plead the

exception is a substantive change in the law. Id. Because procedural statutes that

also change substantive law must be construed to apply only prospectively, we

required a clear and unequivocal expression of legislative intent for the statute to

apply retroactively. Id. This court concluded the language in section 3 of the

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Related

Credeur v. Champion Homes of Boaz, Inc.
6 So. 3d 339 (Louisiana Court of Appeal, 2009)
In Re Succession of James
994 So. 2d 120 (Louisiana Court of Appeal, 2008)
Stewart v. Estate of Stewart
966 So. 2d 1241 (Louisiana Court of Appeal, 2007)
Chance v. American Honda Motor Co., Inc.
635 So. 2d 177 (Supreme Court of Louisiana, 1994)
Cameron Parish School Bd. v. Acands, Inc.
687 So. 2d 84 (Supreme Court of Louisiana, 1997)
In Re Succession of McKay
921 So. 2d 1219 (Louisiana Court of Appeal, 2006)

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