Joseph Gautreaux v. Louisiana Farm Bureau Casualty Insurance Co.

CourtLouisiana Court of Appeal
DecidedDecember 29, 2022
DocketCA-0022-0294
StatusUnknown

This text of Joseph Gautreaux v. Louisiana Farm Bureau Casualty Insurance Co. (Joseph Gautreaux v. Louisiana Farm Bureau Casualty Insurance Co.) 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 Gautreaux v. Louisiana Farm Bureau Casualty Insurance Co., (La. Ct. App. 2022).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

CA 22-294

JOSEPH H. GAUTREAUX

VERSUS

LOUISIANA FARM BUREAU CASUALTY INSURANCE CO.,ET AL.

**********

APPEAL FROM THE SIXTEENTH JUDICIAL DISTRICT COURT PARISH OF ST. MARTIN, NO. 81835 HONORABLE ANTHONY THIBODEAUX, DISTRICT JUDGE

GARY J. ORTEGO JUDGE

Court composed of Sylvia R. Cooks, Chief Judge, Charles G. Fitzgerald, and Gary J. Ortego, Judges.

AFFIRMED, AND REMANDED FOR FURTHER PROCEEDINGS.

Fitzgerald, J., dissents in part with assigned reasons and concurs in part. Wayne J. Lee Heather S. Lonian Stone Pigman Walther Wittmann, L.L.C. 909 Poydras Street, Suite 3150 New Orleans, Louisiana 70112 (504) 581-3200 Counsel for Defendant/Appellant: Louisiana Farm Bureau Casualty Insurance Company

James K. Ordeneaux Matthew T. Habig Plauche Maselli Parkerson, L.L.P. 701 Poydras Street, Suite 3800 New Orleans, Louisiana 70139 (504) 582-1142 Counsel for Defendant/Appellant: Louisiana Farm Bureau Casualty Insurance Company

Charles C. Garrison Caffery, Oubre, Campbell & Garrison, L.L.P. Post Office Drawer 12410 New Iberia, Louisiana 70562 (337) 364-1816 Counsel for Defendant/Appellant: Louisiana Farm Bureau Casualty Insurance Company

Stephen B. Murray, Jr. Stephen B. Murray, Sr. Arthur M. Murray 701 Poydras Street, Suite 4250 New Orleans, Louisiana 70139 (504) 525-8100 Counsel for Plaintiffs/Appellees: Joseph Harvey Gautreaux Individually and On Behalf of Others Similarly Situated

Kenneth W. Dejean Law Offices of Kenneth W. Dejean Post Office Box 4325 Lafayette, Louisiana 70502-4325 (337) 235-5294 Counsel for Plaintiffs/Appellees: Joseph Harvey Gautreaux Individually and On Behalf of Others Similarly Situated Kenneth D. St. Pe Kenneth D. St. Pe, APLC 311 West University Avenue, Suite A Lafayette, Louisiana 70506 (337) 534-4043 Counsel for Plaintiffs/Appellees: Joseph Harvey Gautreaux Individually and On Behalf of Others Similarly Situated

John Randall Whaley Benjamin H. Dampf Whaley Law Firm 6700 Jefferson Highway Building 12, Suite A Baton Rouge, Louisiana 70806 (225) 302-8810 Counsel for Plaintiffs/Appellees: Joseph Harvey Gautreaux Individually and On Behalf of Others Similarly Situated ORTEGO, Judge.

The issue on appeal is whether the trial court erred in its rulings on five

separate motions for summary judgment.

FACTS AND PROCEDURAL HISTORY

In 2014, Plaintiff, Joseph H. Gautreaux (Gautreaux), filed a petition for

damages, penalties, attorney fees, and class certification against Defendant,

Louisiana Farm Bureau Casualty Insurance Company (Farm Bureau). Gautreaux

alleged in his petition that he and potential class members had automobile

insurance policies with Farm Bureau, and that Farm Bureau breached its

contractual obligations under those policies.

One year before filing suit, Gautreaux’s 2008 Ford F-250 was involved in an

automobile accident. Gautreaux made a claim against the collision coverage of his

automobile policy with Farm Bureau. The vehicle was ultimately deemed a total

loss. Thus, to assist in determining the vehicle’s actual cash value, Gautreaux

provided Farm Bureau with a valuation report from the National Automobile

Dealers Association (NADA). Gautreaux’s petition alleged that Farm Bureau

refused to honor the NADA report, relying instead on its own system, known as

the Mitchell Work Center Total Loss (WCTL) computer program.

Plaintiffs contend that the Mitchell WCTL system is a business-to-business

product offered by Mitchell to subscribing insurance companies, such as Farm

Bureau. Plaintiffs argue that the WCTL system generates values that are unfairly

low, that Farm Bureau is aware of this fact, and that Farm Bureau uses the system

to intentionally undervalue total loss vehicles. According to Gautreaux, the WCTL

does not meet the statutory requirements of La.R.S. 22:1892(B)(5) for determining

the actual cash value of their insured’s total loss vehicle. By refusing to pay actual

cash value, Farm Bureau breached the terms and conditions of its policy with Gautreaux and other similarly situated policy holders. The petition therefore seeks

damages representing the difference between the amount tendered by Farm Bureau

and the actual cash value of the total loss vehicles. The petition also asserts that

Farm Bureau breached its duty to adjust claims fairly under La.R.S. 22:1892 and

La.R.S. 22:1973, thereby warranting penalties and attorney fees. Finally, the

petition asserts general tort claims of “fraud, misrepresentation, and duress.”

Many years after the petition was filed, the trial court granted class

certification. Thereafter, a jury trial was set for October 11, 2021. However, two

months prior to trial, Plaintiffs filed a motion for partial summary judgment on the

issue of statutory compliance, specifically seeking judgment that Farm Bureau’s

WCTL system violates the requirements of La.R.S. 22:1892(B)(5). Farm Bureau,

in turn, filed a cross-motion for summary judgment as to compliance with that

statute.

Farm Bureau also filed three other motions for partial summary judgment.

The first sought dismissal of Plaintiffs’ bad faith claims. The second sought

dismissal of Plaintiffs’ claims for fraud, misrepresentation, and duress. The third

sought judgment declaring that La.R.S. 22:1892(B)(5) does not require insurers to

use NADA.

The hearing on all five motions was held on September 22, 2021. The trial

court ruled from the bench. In summary, the trial court granted Plaintiffs’

noncompliance motion, and denied Farm Bureau’s cross-motion. As to Farm

Bureau’s three other motions, their bad faith motion was granted in part and denied

it in part; their fraud motion was also granted in part and denied in part; and their

NADA motion was granted.

2 The trial court’s rulings were reduced to a single written judgment dated

November 15, 2021. The judgment was designated as a final judgment pursuant to

La.Code Civ.P. art. 1915(B)(1). Farm Bureau now appeals.

On appeal, Farm Bureau assigns that the trial court erred in granting

Plaintiffs’ noncompliance motion, in denying Farm Bureau’s cross-motion, in

denying in part its bad faith motion, in denying in part its fraud motion, and in

using confusing decretal language in granting its NADA motion.

ASSIGNMENTS OF ERROR

1. The Trial Court erred in granting Plaintiffs’ Statutory Violation Motion because, at minimum, the uncontradicted fact and expert evidence presented by [Farm Bureau] demonstrated that genuine issues of material fact exist as to whether WCTL complies with La. R.S. 22: 92B(5) and the Trial Court improperly ignored uncontradicted fact and expert testimony and/or alternatively made factual determinations regarding those facts.

2. The Trial Court erred in denying [Farm Bureau’s] Compliance Motion because the uncontested evidence established that WCTL valuations are derived from fair market surveys conducted using qualified retail automobile dealers in the local market as resources and/or determined from generally recognized used motor vehicle industry sources. Alternatively, the motion should have been granted because Plaintiffs have the burden of proving that WCTL violates La. R.S. 22:1892B(5) and the uncontroverted evidence and record established that Plaintiffs cannot meet their burden of proof.

3. The Trial Court erred in denying [Farm Bureau’s] Bad Faith Motion in part, holding that Plaintiffs will be allowed to present a claim for penalties and attorney fees under La. R.S.

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Joseph Gautreaux v. Louisiana Farm Bureau Casualty Insurance Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-gautreaux-v-louisiana-farm-bureau-casualty-insurance-co-lactapp-2022.