Justin Fabre v. M.A. Patout & Son Limited

CourtLouisiana Court of Appeal
DecidedMay 27, 2026
DocketCA-0025-0556
StatusUnknown

This text of Justin Fabre v. M.A. Patout & Son Limited (Justin Fabre v. M.A. Patout & Son Limited) 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
Justin Fabre v. M.A. Patout & Son Limited, (La. Ct. App. 2026).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

25-556

JUSTIN FABRE, ET AL.

VERSUS

M.A. PATOUT & SON LIMITED, ET AL.

**********

APPEAL FROM THE SIXTEENTH JUDICIAL DISTRICT COURT PARISH OF IBERIA, NO. 138544 HONORABLE VINCENT J. BORNE, DISTRICT JUDGE

WILBUR L. STILES JUDGE

Court composed of Elizabeth A. Pickett, Jonathan W. Perry, and Wilbur L. Stiles, Judges.

AFFIRMED. Andy Dupre Ilijana Todorovic The Dupre Law Firm, LLC 521 Valmont Street New Orleans, LA 70115 (985) 855-2553 COUNSEL FOR PLAINTIFFS/APPELLANTS: Justin Fabre Paula Fabre Bill Scully

Patrick Daniel Patrick Daniel Law 4801 Woodway Drive, Suite 440-W Houston, TX 77056 (713) 999-6666 COUNSEL FOR PLAINTIFFS/APPELLANTS: Justin Fabre Paula Fabre Bill Scully

Todd A. Delcambre LeBas Law Offices, APLC 2 Flagg Place, Suite 1 Lafayette, LA 70508 (337) 236-5500 COUNSEL FOR INTERVENOR/APPELLEE: American Interstate Insurance Company

James T. Rivera Jessica W. Marchand Scofield & Rivera, L.L.C. 100 East Vermilion, Suite 301 Lafayette, LA 70501 (337) 235-5353 COUNSEL FOR DEFENDANTS/APPELLEES: M.A. Patout & Son Limited, LLC John Landry

Jeffrey E. McDonald Treadaway Bollinger, LLC 406 North Florida Street, Suite 2 Covington, LA 70433 (985) 273-3123 COUNSEL FOR DEFENDANT/APPELLEE: Louisiana Safety Consultants, Inc. STILES, Judge.

Justin Fabre sustained serious physical injury while performing construction

work at a sugar processing facility. Mr. Fabre and his family members pursued a tort

claim against the facility’s owner as well as its project manager. The trial court,

however, granted Defendants’ motion for summary judgment upon a finding that no

genuine issues of material fact remained as to the facility owner’s status as statutory

employer under the requirements of La.R.S. 23:1061. Plaintiffs appeal. For the

following reasons, we affirm.

FACTS AND PROCEDURAL HISTORY

M.A. Patout & Son Limited, LLC (Patout) operates a number of entities

involved in the harvesting and processing of sugar cane, including the Jeanerette mill

where the October 29, 2021 accident at issue occurred. On that date, Mr. Fabre was

working on the site as an employee of Cleveland J. Billiot, III General Contracting,

Inc. (Billiot), when he was called to perform work on the metal roof over the

facility’s fabrication area. Mr. Fabre maintained that, while performing the work,

“[t]he roof gave way due to its improper maintenance, improper repair, disrepair and

lack of safe means of entry and exit[.]” Mr. Fabre fell through the roof and onto the

floor of the facility. He sustained injuries causing permanent paralysis.

Mr. Fabre filed this suit in February 2022 against Patout and its project

manager John Landry, 1 alleging, among other things, that Defendants failed to

properly maintain the premises and failed to warn of the roof’s substandard condition,

which led to his injury. Paula Fabre, Mr. Fabre’s spouse, sought damages for loss of

consortium. Billy Scully, Mr. Fabre’s brother and coworker, also joined in the

1 Mr. Landry is alternatively referred to as “John Laundry.” We maintain the spelling used in the trial court’s judgment for consistency. petition, alleging that he witnessed the accident and now suffers psychological

damage.

Patout and Mr. Landry denied liability in their answer to the petition and

alternatively alleged that Mr. Fabre was a statutory employee of Patout. Defendants

maintained they were therefore “immune from suit pursuant to Louisiana Workers’

Compensation laws.”

Defendants later filed a motion for summary judgment, asserting that Patout

“is the statutory employer of Plaintiff, Justin Fabre” and, therefore, seeking dismissal

of the plaintiffs’ claims. Defendants maintained that it is undisputed that Billiot was

Mr. Fabre’s direct employer at the time of the accident and that Billiot, as the

contractor, entered into an “Indemnification Agreement and Insurance Requirements”

for work and services at the facility. Defendants noted that the contract specifically

identified Patout as the statutory employer of Billiot and its employees. Referencing

both La.R.S. 23:1061 and the Indemnification Agreement, Defendants maintained

that Patout must be recognized as Mr. Fabre’s statutory employer and, as such, must

be further recognized as immune from liability.

Defendants supported the motion with the Indemnification Agreement signed

by Billiot’s president. Defendants also attached the affidavit of Patout’s Chief

Financial Officer wherein she stated that, on behalf of Patout, she executed the

Indemnification Agreement between Patout and Billiot.

In their opposition, Plaintiffs denied that there was a statutory employment

contract due to a lack of specificity therein. Moreover, even in the presence of a

contract, Plaintiffs maintained that Patout would not be entitled to workers’

compensation protection. Rather, Plaintiffs maintained that Mr. Fabre was instructed

to perform roofing work that was outside the scope of Patout’s trade, occupation, or

2 business as a sugar processor. Further, Plaintiffs maintain that genuine issues of

material fact remain as to the availability of the intentional act exception to the

statutory employer rule as provided by La.R.S. 23:1032(A). In part, Plaintiffs

asserted that Patout sent Mr. Fabre onto the roof despite knowing of its poor

condition and, moreover, Mr. Landry informed Mr. Fabre that the roof was safe and

could support his weight.

Following a hearing, the trial court granted the motion for summary judgment,

dismissing Plaintiffs’ claims against Defendants. The trial court commemorated its

ruling in an April 22, 2026 judgment by which it determined that Patout is the

statutory employer of Mr. Fabre pursuant to La.R.S. 23:1061 and that Plaintiffs, in

turn, failed to provide sufficient evidence to rebut the presumption of statutory

employment. The trial court also determined that “no material issues of fact were

raised by Plaintiff to warrant imposition of the intentional act exclusion to workers’

compensation immunity.” The trial court thus dismissed Plaintiffs’ claims for

personal injuries against Patout and Mr. Landry.2

Plaintiffs appeal, questioning the granting of summary judgment and the

dismissal of their claims.

DISCUSSION

Summary Judgment

Louisiana Code of Civil Procedure Article 966(A)(3) provides that “[a]fter an

opportunity for adequate discovery, a motion for summary judgment shall be granted

if the motion, memorandum, and supporting documents show that there is no

genuine issue as to material fact and that the mover is entitled to judgment as a matter

2 The trial court explained that Plaintiffs’ claim in tort for spoliation of the evidence was not the subject of the proceeding.

3 of law.” While the burden rests with the party moving for summary judgment,

La.Code Civ.P. art. 966(D)(1) further provides that:

Nevertheless, if the mover will not bear the burden of proof at trial on the issue that is before the court on the motion for summary judgment, the mover’s burden on the motion does not require him to negate all essential elements of the adverse party’s claim, action, or defense, but rather to point out to the court the absence of factual support for one or more elements essential to the adverse party’s claim, action, or defense.

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