James D. Madden and Lyda Roberts Madden v. Mary Elizabeth Chumley, In Her Capacity as of the Succession of Johnye Mae Madden

CourtLouisiana Court of Appeal
DecidedSeptember 25, 2019
Docket52,888-CA
StatusPublished

This text of James D. Madden and Lyda Roberts Madden v. Mary Elizabeth Chumley, In Her Capacity as of the Succession of Johnye Mae Madden (James D. Madden and Lyda Roberts Madden v. Mary Elizabeth Chumley, In Her Capacity as of the Succession of Johnye Mae Madden) 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
James D. Madden and Lyda Roberts Madden v. Mary Elizabeth Chumley, In Her Capacity as of the Succession of Johnye Mae Madden, (La. Ct. App. 2019).

Opinion

Judgment rendered September 25, 2019. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 52,888-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

JAMES D. MADDEN AND LYDA Plaintiffs-Appellees ROBERTS MADDEN

versus

MARY ELIZABETH CHUMLEY, Defendant-Appellant IN HER CAPACITY AS EXECUTRIX OF THE SUCCESSION OF JOHNYE MAE MADDEN

Appealed from the Twenty-Sixth Judicial District Court for the Parish of Webster, Louisiana Trial Court No. 76564

Honorable Michael Nerren, Judge

HARPER LAW FIRM, APLC Counsel for Appellant By: Jerald R. Harper Anne E. Wilkes

J. SCHUYLER MARVIN Counsel for Appellees

Before PITMAN, STONE, and STEPHENS, JJ.

PITMAN, J., concurs in the result. STONE, J.

This appeal arises from a possessory action instituted by plaintiffs and

spouses, James D. Madden (“James”) and Lyda Roberts Madden (“Lyda”),

seeking to be recognized as the owners and possessors of the immovable

property in dispute. Following a hearing and bench trial on the merits, the

trial court denied the defendant, Mary Elizabeth Chumley’s (“Beth”),

exception of no cause of action, and granted a judgment of possession in

favor of the plaintiffs. From this judgment, the defendant appeals. We

affirm for reasons other than those assigned by the trial court.

FACTUAL BACKGROUND AND PROCEDURAL HISTORY

James and Lyda filed a possessory action against Beth, in her capacity

as executrix of the Succession of Johnye Mae Madden, seeking to be

recognized as owners and possessors of the immovable property in dispute.

James and Beth are siblings, and the descendants of Johnye Mae Madden

(“Johnye”) and Grady Madden (“Grady”) (collectively referred to as “the

elder Maddens”). The plaintiffs purchased an 88-acre tract of land from Roy

Fincher in 1969 and began construction of their home shortly thereafter. In

1981, with the permission of James and Lyda, began construction of their

home. Upon completion of their home, the elder Maddens moved into their

home (between 1981 and 1982) continued to occupy the residence together

until Grady’s death in 1988. Thereafter, Johnye remained in their home

until her death on January 26, 2016.

On October 24, 2017, the Maddens filed a possessory action alleging

that in January of 2017, Beth filed a preliminary detailed descriptive list of

the property subject to Johnye’s succession, which included the disputed

immovable property that gave rise to this suit (“disputed property”). In the preliminary detailed descriptive list, Beth referred to James as the “former

owner” of the disputed property. On April 6, 2018, Beth filed her answer to

the plaintiff’s petition where she admitted that the property was sold to the

plaintiffs. However, she stipulated that she believed the land was purchased

by the family company, Madden Contracting, LLC, for the benefit of the

Madden family. She also admitted that a residence was built on the disputed

property, but again, upon the information and belief that the construction

costs were paid for through funds from Madden Contracting, LLC.

On August 6, 2018, Beth received notice from the trial court setting a

bench trial on the merits for September 26, 2018. Thereafter, the plaintiffs

sought to amend their petition to include the following paragraph:

Plaintiffs may use expert opinions in the prosecution of this matter to assist the trier of fact. If so, their fees and costs should be taxed as costs of the court and assessed against the defendant.

There is some ambiguity in the record as to the date that the plaintiffs’

motion to amend was filed. The clerk’s office file-stamped the motion to

amend on August 29, 2018; however, the record indicates that the trial court

granted the plaintiffs’ motion to amend on August 23, 2018. Beth received a

citation without a copy of the plaintiffs’ amended petition on September 11,

2018. Counsel for Beth sent correspondence to the trial judge requesting a

status conference to address the following issues: 1) the current stay order in

the related succession proceeding which precluded any further filings; and 2)

the plaintiffs’ amendment which indicated the possibility of expert witnesses

offering testimony at the bench trial.

A week before trial on September 19, 2018, Beth filed a motion to

continue, a motion in limine “to exclude and/or limit the trial testimony of 2 Morris Guin and to limit the testimony of James and Lyda Madden,” and an

exception of no cause of action. On September 26, 2018, the trial court

heard arguments on the motion to continue only, and subsequently granted

it. The trial court set the new trial date for October 18, 2018.

On October 18, 2018, before trial began, the court heard arguments on

Beth’s exception of no cause of action, which was ultimately denied. In

addition, Beth’s motion in limine was granted in part and denied in part.

Immediately after the pronouncement of the ruling, the bench trial began.

The plaintiffs called Beth, James, Morris Guin, and Charles Smith to testify.

Beth elected, however, to refrain from calling any witnesses to testify. The

trial court subsequently ruled in favor of the plaintiffs, finding that James

and Lyda carried their burden entitling them to a judgment of possession.

This devolutive appeal ensued.

DISCUSSION

Applicable Law

The possessory action is one brought by the possessor of immovable

property or of a real right therein to be maintained in his possession of the

property or enjoyment of the right when he has been disturbed, or to be

restored to the possession or enjoyment thereof when he has been evicted.

La. C.C.P. art. 3655. In a possessory action, the burden of proof is upon the

plaintiff to establish the essential elements thereof. Strain v. Aaron, 49,647

(La. App. 2 Cir. 2/27/15), 162 So. 3d 553; Saunders v. Hollis, 44,490 (La.

App. 2d Cir. 8/19/09), 17 So. 3d 482, writ denied, 2009–2221 (La.12/18/09),

23 So. 3d 945.

To maintain the possessory action, the possessor must allege and

prove that (1) he had possession of the immovable property or real right 3 therein at the time the disturbance occurred; (2) he and his ancestors in title

had such possession quietly and without interruption for more than a year

immediately prior to the disturbance, unless evicted by force or fraud; (3) the

disturbance was one in fact or in law, as defined in La. C.C.P. art. 3659; and

(4) the possessory action was instituted within a year of the disturbance. La.

C.C.P. art. 3658.

Disturbances of possession which give rise to the possessory action

are of two kinds: disturbance in fact and disturbance in law. A disturbance

in fact is an eviction, or any other physical act which prevents the possessor

of immovable property or of a real right therein from enjoying his

possession quietly, or which throws any obstacle in the way of that

enjoyment. A disturbance in law is the execution, recordation, registry, or

continuing existence of record of any instrument which asserts or implies a

right of ownership or to the possession of immovable property or of a real

right therein, or any claim or pretension of ownership or right to the

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James D. Madden and Lyda Roberts Madden v. Mary Elizabeth Chumley, In Her Capacity as of the Succession of Johnye Mae Madden, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-d-madden-and-lyda-roberts-madden-v-mary-elizabeth-chumley-in-her-lactapp-2019.