Jrb Holdings, L.L.C. and/or Jrb Holdings, L.L.C. in Its Representative Capacity for Mst, L.L.C., and/or John Ray Broussard v. Stephen J. Oats, Individually and/or Stephen J. Oats, a Professional Law Corporation, Cearley W. Fontenot and Oats and Marino, a Partnership of Professional Corporations

CourtLouisiana Court of Appeal
DecidedOctober 16, 2024
DocketCA-0024-0008
StatusUnknown

This text of Jrb Holdings, L.L.C. and/or Jrb Holdings, L.L.C. in Its Representative Capacity for Mst, L.L.C., and/or John Ray Broussard v. Stephen J. Oats, Individually and/or Stephen J. Oats, a Professional Law Corporation, Cearley W. Fontenot and Oats and Marino, a Partnership of Professional Corporations (Jrb Holdings, L.L.C. and/or Jrb Holdings, L.L.C. in Its Representative Capacity for Mst, L.L.C., and/or John Ray Broussard v. Stephen J. Oats, Individually and/or Stephen J. Oats, a Professional Law Corporation, Cearley W. Fontenot and Oats and Marino, a Partnership of Professional Corporations) 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.

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Jrb Holdings, L.L.C. and/or Jrb Holdings, L.L.C. in Its Representative Capacity for Mst, L.L.C., and/or John Ray Broussard v. Stephen J. Oats, Individually and/or Stephen J. Oats, a Professional Law Corporation, Cearley W. Fontenot and Oats and Marino, a Partnership of Professional Corporations, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

24-8

JRB HOLDINGS, LLC AND/OR JRB HOLDINGS, LLC IN ITS REPRESENTATIVE CAPACITY FOR MST, LLC AND/OR JOHN RAY BROUSSARD

VERSUS

STEPHEN J. OATS, INDIVIDUALLY AND/OR STEPHEN J. OATS, A PROFESSIONAL LAW CORPORATION, CEARLEY W. FONTENOT AND OATS & MARINO, A PARTNERSHIP OF PROFESSIONAL CORPORATION

**********

APPEAL FROM THE FIFTHTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, 20160932 HONORABLE MICHELLE M. BREAUX, DISTRICT JUDGE

LEDRICKA J. THIERRY JUDGE

Court composed of Jonathan W. Perry, Ledricka J. Thierry, and Guy E. Bradberry, Judges.

AFFIRMED. Kevin R. Duck Duck Law Firm, LLC 5040 Ambassador Caffery Pkwy., Ste. 200 Lafayette, LA 70508 (337) 406-1144 COUNSEL FOR PLAINTIFFS/APPELLANTS JRB Holdings, LLC and/or JRB Holdings, LLC in its Representative Capacity for MST, LLC and/or John Ray Broussard

J. Clemille Simon Simon Law Offices 122 Representiave Row P.O. Box 52242 Lafayette, LA 70505 (337) 232-2000 COUNSEL FOR PLAINTIFFS/APPELLANTS JRB Holdings, LLC and/or JRB Holdings, LLC in its Representative Capacity for MST, LLC and/or John Ray Broussard

Edward P. Landry Landry, Watkins, Repsake & Breaux 211 E. Main St. P.O. Drawer 12040 New Iberia, LA 70562 (337) 367-2715 COUNSEL FOR DEFENDANTS/APPELLEES Stephen J. Oats, Individually and/or Stephen J. Oats, a Professional Law Corporation, Earley W. Fontenot and Oats & Marino, a Partnership of Professional Corporations THIERRY, Judge.

This action stems from a legal malpractice lawsuit that was dismissed on an

exception of no right of action. Plaintiffs appeal the trial court’s granting of the

exception. For the reasons that follow, we affirm the findings of the trial court.

FACTS AND PROCEDURAL HISTORY

On January 6, 2009, John Ray Broussard (“JRB”) formed a company called

Mason Specialty Tools, LLC (“MST”). He was the sole member until the first

amended operating agreement of MST assigned 55% ownership interest to Stephen

Domingue (“Domingue”) and 45% ownership interest to JRB Holdings, LLC

(“JRBH”). After a period of time, JRB began to suspect that Domingue was misusing

MST’s funds. Therefore, on or about July 11, 2014, JRB retained the law firm of

Oats & Marino to represent him and/or his businesses. The record does not contain

a formal attorney-client contract. Rather, the record reflects an engagement letter

signed on July 11, 2014, addressed to “John Ray,” and signed by John Ray Broussard

and Stephen J. Oats, an attorney in the law firm of Oats & Marino located in

Lafayette, Louisiana. The engagement letter outlines the billing procedures set forth

by Oats & Marino, with John Ray Broussard’s signature evidencing his agreement

to employ Oats & Marino.

On August 5, 2014, Oats & Marino filed a petition for appointment of a

receiver with JRB identified as the plaintiff and Domingue and MST identified as

the defendants. The petition alleged, inter alia, that Domingue grossly mismanaged

the business and misused the assets of MST. Domingue filed several pleadings in

response, including a motion to strike and/or dilatory exceptions of nonconformity,

vagueness and ambiguity, lack of procedural capacity, and peremptory exception of

no right of action. After a hearing on January 12, 2015, the trial court collectively granted all the exceptions and dismissed without prejudice the petition for

appointment of receiver.

On February 20, 2015, Oats & Marino filed a new petition for damages against

Stephen Domingue. The plaintiff identified in this suit was JRBH. Domingue

responded with an exception of no right of action, arguing that JRBH had no right

of action to bring those claims, as MST was the proper party to do so via a derivative

action. On April 28, 2015, Oats & Marino filed a first supplemental and amended

petition for damages. However, the amended petition did not address or attempt to

cure Domingue’s arguments set forth in its exception of no right of action.

JRB subsequently retained new counsel and filed a second supplemental and

amended petition for damages, adding MST as a petitioner. The suit was eventually

dismissed on a joint motion to dismiss following settlement.

In June or July of 2015, Defendants prepared a Receipt, Release, and

Indemnity Agreement (“2015 Release”), which purported to hold harmless

Defendants from any claims arising out of their malpractice. This Release was never

signed. Specifically, the Release said that John Ray Broussard and JRB Holdings,

LLC:

release, acquit and forever discharge OATS & MARINO…of and from any and all past and present claims, demands, causes of action and/or rights of action…in anyway related to the delivery of professional legal serviced provided to [John Ray Broussard and JRB Holdings, LLC] by OATS & MARINO from July 11, 2014 through the date of this Agreement….

On February 22, 2016, JRB Holdings, L.L.C. and/or JRB Holdings, L.L.C. in

its representative capacity for MST, L.L.C., and/or John Ray Broussard

(“Plaintiffs”) filed a legal malpractice petition against Stephen J. Oats, individually,

and/or Stephen J. Oats, a professional law corporation, Cearley W. Fontenot, and

2 Oats & Marino, a partnership of professional corporations (“Defendants”). Plaintiffs

allege, inter alia, that Defendants “failed to investigate all potential causes of action

and failed to file suit asserting all potential causes of action against said petitioners.”

In conclusion, Plaintiffs allege:

As a result of the defendants’ malpractice, defendants allowed numerous causes of action to prescribe and thus, have deprived petitioners of the right to recover damages that would have otherwise been due and owing to said petitioners arising from all of the potential causes of action defendants were hired to investigate and pursue.

Defendants filed their answer, exceptions, and affirmative defenses on

January 9, 2017. The exceptions filed on this date did not include a no right of action

exception, but rather included prematurity, vagueness or ambiguity, prescription,

peremption, and no cause of action. Various discovery requests and related motions

were filed thereafter.

On July 20, 2018, MST purported to assign all rights and interest in the legal

malpractice lawsuit to JRBH. This assignment was signed by Stephen Domingue,

managing member of MST.

On March 16, 2023, Defendants filed a peremptory exception of no right of

action. It is this exception which is the basis of this appeal. The exception of no right

action was heard on August 14, 2023. The trial court orally ruled and granted the

exception and dismissed all Plaintiffs’ claims. It issued written reasons shortly

thereafter. The trial court wrote, in part:

The issue to be decided in this Peremptory Exception of No Right of Action was whether the Plaintiffs (JRBH or Mr. Broussard) had a personal right to bring the legal malpractice claim asserted in their petition or whether this claim actually belonged to Mason Specialty Tools, LLC (MST) and/or its members derivatively. This court held that neither JRB Holdings, LLC nor John Ray Broussard had a personal right of action to initiate this lawsuit. The legal malpractice claim asserted belonged to Mason Specialty Tools, LLC (MST) through a derivative action.

3 Plaintiffs have now appealed the ruling on the exception of no right of action,

asking that this court reverse the trial court’s ruling.

ASSIGNMENTS OF ERROR

The Plaintiffs allege the following assignments of error on appeal:

1.

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Jrb Holdings, L.L.C. and/or Jrb Holdings, L.L.C. in Its Representative Capacity for Mst, L.L.C., and/or John Ray Broussard v. Stephen J. Oats, Individually and/or Stephen J. Oats, a Professional Law Corporation, Cearley W. Fontenot and Oats and Marino, a Partnership of Professional Corporations, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jrb-holdings-llc-andor-jrb-holdings-llc-in-its-representative-lactapp-2024.