Joseph Bartlett v. A-1 Service Company of Houma, LLC, Sugarland Shopping Center Associates, LLC, Family Dollar Stores of Louisiana, Inc. and ABC Insurance Company

CourtLouisiana Court of Appeal
DecidedApril 17, 2024
Docket2023CA1016
StatusUnknown

This text of Joseph Bartlett v. A-1 Service Company of Houma, LLC, Sugarland Shopping Center Associates, LLC, Family Dollar Stores of Louisiana, Inc. and ABC Insurance Company (Joseph Bartlett v. A-1 Service Company of Houma, LLC, Sugarland Shopping Center Associates, LLC, Family Dollar Stores of Louisiana, Inc. and ABC Insurance Company) 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
Joseph Bartlett v. A-1 Service Company of Houma, LLC, Sugarland Shopping Center Associates, LLC, Family Dollar Stores of Louisiana, Inc. and ABC Insurance Company, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

2023 CA 1016

JOSEPH BARTLETT

VERSUS

A- 1 SERVICE COMPANY OF HOUMA, LLC, SUGARLAND SHOPPING CENTER ASSOCIATES, LLC, FAMILY DOLLAR STORES OF LOUISIANA, INC. AND ABC INSURANCE COMPANY

Judgment Rendered: APR 17 2024

Appealed from the 17th Judicial District Court In and for the Parish of Lafourche State of Louisiana Case No. C- 132317

The Honorable Maria M. Abel, Judge Presiding

Richard E. Wilson Counsel for Plaintiffs/ Appellants Lake Charles, Louisiana Barrett Bartlett and Courtney Bartlett Collins on behalf of their deceased father, Joseph Bartlett

Adam J. Boyer Counsel for Defendant/ Appellee R. Todd Musgrave A-1 Service Company of Houma, LLC New Orleans, Louisiana

Bruce S. Johnston Counsel for Defendants/ Appellees Metairie, Louisiana Sugarland Shopping Center Associates, LLC and Family Dollar Stores of Louisiana, Inc.

BEFORE: GUIDRY, C. J., CHUTZ, AND LANIER, JJ. LANIER, J.

In this slip and fall action, plaintiffs challenge the trial court's judgment

granting defendants' summary judgment and dismissing their claims with

prejudice. We reverse and remand.

FACTS AND PROCEDURAL HISTORY

Plaintiff, Joseph Bartlett, alleged that he sustained injuries outside of the

Family Dollar Store in Raceland, Louisiana. Mr. Bartlett described the incident in

his petition as slipping and falling in the parking lot of the shopping center " when

his feet slipped out from under him and he fell on his back in wet tar which was

being painted onto the blacktop of the parking area." Mr. Bartlett thereafter filed a

petition for damages, naming as defendants A- 1 Service Company of Houma, LLC

A- 1), the company responsible for re -tarring the parking lot; Sugarland Shopping

Center Associates, LLC ( Sugarland), the shopping center that owned the parking

lot; and Family Dollar Stores of Louisiana, Inc. ( Family Dollar). Over three years

after this incident, Mr. Bartlett died from unrelated causes.' Subsequently, his

children, Barrett Bartlett and Courtney Bartlett Collins, moved to be substituted as

party plaintiffs (plaintiffs).

In response to Mr. Bartlett' s petition, A- 1 filed a motion for summary

judgment, asserting there is no genuine issue of material fact with respect to

liability because plaintiffs are unable to prove that a defect/ condition of the parking

lot presented an unreasonable risk of harm to Mr. Bartlett and, therefore, plaintiffs

cannot carry their burden of proof.' A- t maintained the " active" construction area

in the parking lot was clearly visible, marked with " large construction barrels,

large machinery, and construction workers." A- 1 argued it had no duty to

protect/warn Mr. Bartlett of the construction/ tar in the parking lot as it was " open

Mr. Bartlett gave his deposition testimony prior to his death.

Two years prior, A- 1 filed a motion for summary judgment raising these identical arguments. Said motion was continued without date by agreement of the parties.

2 and obvious" to all and did not present an unreasonable risk of harm. In support of

its motion, A- 1 submitted a copy of Mr. Bartlett's deposition and a copy of the

petition for damages. 3

In response, the plaintiffs filed a cross motion for summary judgment,

seeking a denial of A -I' s motion for summary judgment. In its motion, which also

served as an opposition to A- I' s motion for summary judgment, plaintiffs disputed

A- I' s position that the parking lot was an open and obvious risk, that it was an

active construction site, or that there were any warning signs near the entrance/ exit

of Family Dollar. Plaintiffs maintained there were no workers actively spraying tar

on any part of the parking lot when Mr. Bartlett walked out of Family Dollar.

Plaintiffs acknowledged the adjoining lot—waiting to be sprayed—contained some

equipment but disputed that work was being done or tar was being sprayed.

Plaintiffs argued that A- I breached its duty to warn of a hazardous condition it

created and that the failure to warn was a " but -for cause" of the accident and Mr.

Bartlett's injuries. In support of their motion, plaintiffs submitted the Lafourche

3 Referenced in Mr. Bartlett's deposition is a photograph that allegedly shows the condition of the parking lot on the day of the incident. Said photo was attached to the deposition when it was initially submitted by A- 1 in support of its original motion for summary judgment. However, according to our review of the record, the photograph was not attached to the copy of Mr. Bartlett's deposition that was submitted in support of the motion for summary judgment that is before us now. Prior to its amendment in 2023, La. Code Civ. P. art. 966 provided that parties were required to file their supporting documents with the motion and memorandum in order for such supporting documents to be considered; references to documents elsewhere in the record were not permissible. La. Code Civ. P. art. 966( D)( 2); see La. Code Civ. P. art. 966, Comments - 2015 Comment ( k) ( noting that the 2015 revision made it clear that the court can only consider documents filed in support of or in opposition to the motion, which differs from the Federal Rules of Civil Procedure Rule 56( c)( 3), which allows the court to consider other materials in the record); see also Troncoso v, Point Carr Homeowners Association, 2022- 0530

La. App. 1 Cir. 1/ 10/ 23), 360 So. 3d 901, 914- 915 ( discussing former Article 966( A)(4) and D)( 2)). However, Article 966, as amended, now permits such supporting documents to be " filed or referenced" and mandates that a trial court shall consider only those documents " filed or

referenced" in support of or in opposition to a motion for summary judgment. See La. Code Civ. P. art. 966( A)(4)( a) and ( D)( 2) as amended by 2023 La. Acts No. 317, § 1. This court recently decided that the 2023 amendments to Article 966( A)( 4) and ( D)( 2) are substantive because they changed the law by creating an alternative means by which a party may have their supporting documents considered in support of and in opposition to a motion for summary judgment and as such, created additional duties for a party seeking to reference supporting documents. Ricketson v. McKenzie, 2023- 0314 ( La. App. 1 Cir. 10/ 4/ 23), --- So. 3d ---, 2023 WL 7037495, * 4. Accordingly, we apply the version of Article 966( D)(2) that was in effect at the time of the hearing in this matter, and our cue novo review will not include the photograph submitted by A-1.

3 Parish Sheriffs Office incident report, photographs of the parking lot, and a

surveillance video.' Plaintiffs alleged this evidence supported a finding that it was

not until after Mr. Bartlett' s accident that measures were taken to rope off the

parking lot and the entrance/ exit of Family Dollar.

Sugarland and Family Dollar filed a motion for summary judgment adopting

A- I' s arguments regarding the open and obvious nature of the condition of the

parking lot. Sugarland and Family Dollar asserted further there was no genuine

issue of material fact with respect to their liability because plaintiffs cannot

produce any evidence of negligence on their part or any evidence they were in

custody or control of the parking lot and the project to resurface it at the time of the

incident.

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Joseph Bartlett v. A-1 Service Company of Houma, LLC, Sugarland Shopping Center Associates, LLC, Family Dollar Stores of Louisiana, Inc. and ABC Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-bartlett-v-a-1-service-company-of-houma-llc-sugarland-shopping-lactapp-2024.