In the matter of the minors Josiah Carrier, Amelia Carrier and Jack Carrier

CourtLouisiana Court of Appeal
DecidedDecember 27, 2024
Docket2024CA0512
StatusUnknown

This text of In the matter of the minors Josiah Carrier, Amelia Carrier and Jack Carrier (In the matter of the minors Josiah Carrier, Amelia Carrier and Jack Carrier) 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 the matter of the minors Josiah Carrier, Amelia Carrier and Jack Carrier, (La. Ct. App. 2024).

Opinion

r R0111- 11M.mrsig

STATE OF LOUISIANA

COURT OF APPEAL

1 IN THE MATTER OF THE MINORS J. C., A.C., AND J. C.

DEC 2 7 2024 DATE OF JUDGMENT.•

ON APPEAL FROM THE TWENTY-FIRST JUDICIAL DISTRICT COURT PARISH OF LIVINGSTON, STATE OF LOUISIANA NUMBER 181544, DIVISION C

HONORABLE ERIKA W. SLEDGE, JUDGE

Wyman E. Bankston Counsel for Appellee Livingston, Louisiana W.S. C.

A. Gregory Rome Counsel for Appellant Jennifer Racca V.L.T. Baton Rouge, Louisiana

Disposition: REVERSED AND REMANDED.

In order to protect the identity of the minors involved in this appeal and to ensure their confidentiality, the initials of the parties and the minors are used throughout this opinion. See Uniform Rules, Courts of Appeal, Rule 5- 2. Chutz, J.

Petitioner, V.L.T., appeals a judgment dismissing, on an exception of no right

of action, her petition for confirmation as provisional tutor of her three minor

grandchildren with authority to compromise their claims and vacating a prior order

appointing her as the minors' provisional tutor. We reverse and remand.

FACTUAL AND PROCEDURAL HISTORY

Three children were born of the relationship between J.P.C. and W.S. C.: J. C.

in 2016; A.C. in 2017; and J. C. in 2018. On February 21, 2023, W.S. C. shot and

killed J. P.C. Several months later, a grand jury pretermitted consideration of the

killing of J.P. C. The record contains no evidence W.S. C. was ever arrested or

charged with any offense in connection with the shooting. The three children have

remained in W.S. C.' s physical custody and care.

Petitioner is the paternal grandmother of the minor children. On February 8,

2024, she filed an emergency petition for confirmation as the children' s provisional

tutor and for authority to compromise their claims. Petitioner alleged it was

necessary for her to be appointed as the children' s provisional tutor so that she could

protect their financial interests, in part by filing a wrongful death suit against their

mother W.S. C. Additionally, petitioner alleged the children have a vested interest

in the proceeds of their father' s life insurance policy because their mother, who is

the named beneficiary, may be disqualified from receiving the proceeds under La.

R. S. 22: 901 ( i.e., the Slayer Statute).' The trial court signed an order appointing

Louisiana Revised Statutes 22: 901( D)( 1) provides:

No beneficiary ... under any personal insurance contract shall receive from the insurer any benefits under the contract accruing upon the death ... of the individual insured when the beneficiary ... is either:

a) Held by a final judgment of a court of competent jurisdiction to be criminally responsible for the death ... of the individual insured.

b) Judicially determined to have participated in the intentional, unjustified killing of the individual insured.

W petitioner as the children' s provisional tutor on the day the petition was filed.

Further, W.S. C. was ordered to show cause why petitioner should not be confirmed

as the children' s provisional tutor.

In response, W.S. C. filed an answer, a peremptory exception raising the

objection of no right of action, and a dilatory exception raising the objection of

prematurity. Following a hearing, the trial court rendered judgment in favor of

W.S. C. on the grounds that she was the children' s natural tutor and there were no

pending criminal charges against her as a result of J.P. C.' s death. On April 3, 2023,

the trial court signed a judgment sustaining W.S. C.' s exception of no right of action

and dismissing the petition of the children' s grandmother to be confirmed as their

provisional tutor with authority to compromise their claims. Rather than reaching

the merits of the exception of prematurity, the trial court overruled it on the grounds

of mootness. The trial court' s judgment also vacated the prior order appointing

petitioner as the children' s provisional tutor. Petitioner now appeals.

APPLICABLE LAW

The purpose of the peremptory exception of no right of action is to determine

whether the plaintiff belongs to the class of persons to whom the law grants the cause

of action asserted. The exception assumes the petition states a valid cause of action

for some person and questions whether the plaintiff is a member of the class that has

a legal interest in the subject matter of the litigation. HPC Biologicals, Inc. v.

UnitedHealtheare of Louisiana, Inc., 16- 0585 ( La. App. 1st Cir. 5/ 26/ 16), 194

So. 3d 784, 792. The exception does not raise the question of the plaintiff' s ability

to prevail on the merits nor the question of whether the defendant may have a valid

defense. Pearce v. Lagarde, 20- 1224 ( La. App. lst Cir. 10/ 7/ 21), 330 So. 3d 1160,

1167, writ denied, 22- 00010 ( La. 2/ 22/ 22), 333 So. 3d 446.

To prevail, the party raising the exception of no right of action must show the

plaintiff does not have an interest in the subject matter ofthe suit or the legal capacity 3 to proceed with the suit. Pearce, 330 So.3d at 1167. Particularly when the protection

of minors' rights is involved in a tutorship proceeding, a liberal construction of who

is an interested party would appear to be appropriate. See In re Tutorship of

Werling, 459 So. 2d 758, 764 (La. App. 4th Cir. 1984). Where doubt exists regarding

the appropriateness of an objection of no right of action, it should be resolved in

favor of the plaintiff. Pearce, 330 So. 3d at 1167.

Trial court rulings maintaining exceptions of no right of action are reviewed

de novo on appeal because they involve questions of law. When evidence is

introduced to support or controvert an exception of no right of action, however, a

trial court' s factual findings are reviewed under the manifest error -clearly wrong

standard of review. Pearce, 330 So. 3d at 1167.

DISCUSSION

On appeal, petitioner argues the trial court erred in sustaining the exception of

no right of action, in vacating the prior order granting her provisional tutorship of

the children, and in denying her an opportunity to amend her petition. She maintains

she meets all of the qualifications to be appointed provisional tutor of the children

and is a member of the class of persons who have a legal interest in the subject matter

of the litigation in order to preserve the rights and property of her minor

grandchildren. Petitioner contends the children' s rights and property include a

financial interest in their father' s life insurance policy, as well as a claim against

their mother for the wrongful death of their father.

In opposition, W.S. C. contends petitioner has no right to be granted

provisional tutorship of the minor children because they have a surviving parent and

natural tutor. She argues the rights petitioner seeks to assert on behalf of the children

lie with her, as the children' s mother and natural tutor.

It is true that upon the death of a parent, the tutorship of minor children

belongs of right to the surviving parent as a tutorship by nature. See La. C. C. art.

El 250. Nevertheless, the flaw with W.S. C.' s position, which the trial court apparently

accepted, is that it ignores those situations in which a person other than a surviving

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Related

Walker v. State Farm Mut. Auto. Ins. Co.
765 So. 2d 1224 (Louisiana Court of Appeal, 2000)
In Re Tutorship of Werling
459 So. 2d 758 (Louisiana Court of Appeal, 1984)
Griffin v. BSFI WESTERN E & P, INC.
812 So. 2d 726 (Louisiana Court of Appeal, 2002)
Griffith v. Roy
269 So. 2d 217 (Supreme Court of Louisiana, 1972)
Cox v. Gaylord Container Corp.
897 So. 2d 1 (Louisiana Court of Appeal, 2005)
HPC Biologicals, Inc. v. UnitedHealthcare of Louisiana, Inc.
194 So. 3d 784 (Louisiana Court of Appeal, 2016)
In re the Tutorship of the Property of Werling
518 So. 2d 1177 (Louisiana Court of Appeal, 1988)
In re the Tutorship of Watts
681 So. 2d 74 (Louisiana Court of Appeal, 1996)

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