Joshua J. Foster v. the City of Leesville

CourtLouisiana Court of Appeal
DecidedMarch 25, 2020
DocketCA-0020-0047
StatusUnknown

This text of Joshua J. Foster v. the City of Leesville (Joshua J. Foster v. the City of Leesville) 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
Joshua J. Foster v. the City of Leesville, (La. Ct. App. 2020).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

CA 20-47

JOSHUA J. FOSTER, ET AL.

VERSUS

THE CITY OF LEESVILLE

**********

APPEAL FROM THE THIRTIETH JUDICIAL DISTRICT COURT PARISH OF VERNON, NO. 87,304 HONORABLE C. ANTHONY EAVES, DISTRICT JUDGE

D. KENT SAVOIE

JUDGE

Court composed of Shannon J. Gremillion, D. Kent Savoie, and Jonathan W. Perry, Judges.

MOTION TO SUPPLEMENT RECORD GRANTED. Michael Dean Hebert Becker & Hebert 201 Rue Beauregard Lafayette, LA 70508 (337) 233-1987 COUNSEL FOR DEFENDANT/APPELLANT: The City of Leesville

Brian D. Cespiva Attorney at Law 711 Washington Street Alexandria, LA 71301 (318) 448-0905 COUNSEL FOR DEFENDANT/APPELLANT: Leesville Muncipal Fire and Police Civil Service Board

Mark Felipe Vilar Aaron L. Green Vilar & Green 1450 Dorchester Drive Alexandria, LA 71315 (318) 442-9533 COUNSEL FOR PLAINTIFFS/APPELLEES: Joshua J. Foster Leonard R. Edwards Horace C. Condon Amanda G. Lawrence Stacy B. Dixon Ronald K. Bush Michael D. Allen William Tibbits Dennis Doherty Eric J. Baker Brandon Strickland SAVOIE, Judge.

Defendant-Appellant, City of Leesville, moves this court to supplement the

record in the instant appeal. For the reasons given herein, we grant the motion.

The instant case involves the interpretation of La.R.S. 33:1996, a statute

providing for certain minimum amounts of vacation leave for firefighters.

Appellant states that the instant case was previously before this court in docket

number 17-1106, wherein it was reversed and remanded for further proceedings

consistent with this court’s opinion. Foster v. City of Leesville, 17-1106 (La.App.

3 Cir. 6/13/18), 250 So.3d 302. The instant appeal, Appellant asserts, is from a

judgment rendered after the remand was ordered by this court and presents one of

the same issues of law previously presented in docket number 17-1106. Appellant

maintains that in pursuit of the instant appeal, it relies in part upon the entire record

in docket number 17-1106. Since the record submitted by the lower court does not

include any of the proceedings included in docket number 17-1106, Appellant

moves to supplement the record of the instant appeal with the record in 17-1106.

In opposition, Plaintiffs-Appellees, Joshua J. Foster, Leonard R. Edwards,

Horace C. Condon, Amanda G. Lawrence, Stacy B. Dixon, Ronald K. Bush,

Michael D. Allen, William Tibbits, Dennis Doherty, Eric J. Baker, and Brandon

Strickland, argue that it is undisputed that for many years, Appellant failed to

provide its firemen with the annual leave required by La.R.S. 33:1996. Then on

December 5, 2013, the trial court granted summary judgment in favor of

Appellees, concluding that La.R.S. 33:1996 applies to Appellant. Appellees assert

that the matter proceeded to trial a second time to determine how to properly

account for the years Appellants failed to provide its firemen with the annual leave

under La.R.S. 33:1966 and ruled in favor of appellees on June 17, 2019. Appellees urge that Appellant’s sole assignment of error relates to the June

17, 2019 judgment, only, and the evidence introduced at the June 17, 2019 trial.

The only reason Appellant seeks to add the prior record as an exhibit, Appellees

contend, is because it is attempting to rely on documents not introduced into

evidence at the June 17, 2019 trial. As such, Appellees object to Appellant’s

motion to supplement, arguing that it attempts to expand the exhibits introduced at

the June 17, 2019 trial. Appellees complain that instead of specifying specific

documents to add to the already lodged record, Appellant seeks a blanket order to

supplement the record with the entirety of the prior record consisting of 623 pages.

Appellees argue that Appellant has not made the requisite showing that this type of

expansive supplement is necessary or required by the Louisiana Code of Civil

Procedure or the Uniform Rules—Courts of Appeal. In support of their argument,

Appellees cite Uniform Rules, Courts of Appeal, Rule 2-1.7, which reads

(emphasis added):

The record shall include exact legible copies of all documentary evidence and other evidence (including depositions filed in evidence) in the order in which such evidence was filed. If it is necessary that the original of any evidence be filed, such original must be filed separately and not attached to the record; however, there must be proper reference in the record showing such filing. No record of another case (or prior record in the same titled and numbered case) shall be included in the record, unless such other record has been introduced in evidence (at trial) in the case on appeal or on writs, in which event such other record shall accompany the record as an exhibit.

According to Appellees, the prior record was not introduced into evidence at trial.

“Evidence not properly and officially offered and introduced cannot be considered,

even if it is physically placed in the record.” Denoux v. Vessel Management

Services, Inc., 07-2143, p. 5 (La. 5/21/08), 983 So.2d 84, 88. As such, Appellees

2 conclude that this court’s review on appeal is limited to the evidence introduced at

trial.

Next, Appellees acknowledge that the record of the instant case does not

include the original petition, Appellant’s answer, or any orders, minutes entries,

judgments, or written reasons for judgment that predate the prior appeal.

Appellees assert that they have no objection to supplementing the record with these

documents. Appellees, however, object to Appellant’s “carte blanche” motion to

supplement the record with the entire record from a separate appeal which is

prohibited by Rule 2-1.7. Appellees urge that it would burden this court and the

record in this matter by including a bulky, voluminous prior filing not introduced

into evidence at trial and that has nothing to do with Appellant’s sole assignment

of error related to the June 17, 2019 judgment. Pursuant to Uniform Rules—

Courts of Appeal, Rule 2-1.12, “Bulky or cumbersome documents, exhibits, and

other physical or corporeal evidence should not be filed with the record, unless

otherwise ordered by the court.” Lastly, Appellees urge that it would be improper

to allow Appellant a second bite at the apple on appeal by introducing documents

not introduced into evidence at trial in an effort to disturb the trial court’s properly

rendered judgment.

In reply, Appellant asserts that in the first appeal, this court vacated the trial

court’s ruling regarding the proper interpretation of La.R.S. 33:1996. On remand,

Appellant states, the trial court rendered the same judgment in favor of Appellees.

Because the precise issue and facts presented in this identical appeal have been

before this court, Appellant urges that the same facts, evidence, and pleadings

should be included in the present record. Considering that the parties are in

substantial agreement on most of what needs to be supplemented in the current 3 appeal record, Appellant avers that there is little in the prior record that would not

supplement the present record on appeal—the surplus is harmless. Nonetheless, in

an effort to bring closure to this matter, Appellant provided a list of 46 documents

found in the prior record that it deems should be added to the present record.

Appellant maintains that this court is authorized to supplement the record pursuant

to La.Code Civ.P. art.

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Related

Denoux v. Vessel Management Services, Inc.
983 So. 2d 84 (Supreme Court of Louisiana, 2008)
Foster v. City of Leesville
250 So. 3d 302 (Louisiana Court of Appeal, 2018)

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Bluebook (online)
Joshua J. Foster v. the City of Leesville, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joshua-j-foster-v-the-city-of-leesville-lactapp-2020.