Lafayette Care Center v. Betty Mouton

CourtLouisiana Court of Appeal
DecidedAugust 13, 2014
DocketWCW-0014-0455
StatusUnknown

This text of Lafayette Care Center v. Betty Mouton (Lafayette Care Center v. Betty Mouton) 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
Lafayette Care Center v. Betty Mouton, (La. Ct. App. 2014).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

WCW 14-455

LAFAYETTE CARE CENTER

VERSUS

BETTY MOUTON

**********

ON APPLICATION FOR SUPERVISORY WRITS FROM THE OFFICE OF WORKERS’ COMPENSATION, DISTRICT 04 DOCKET NO. 13-00790 HEARING OFFICER ADAM JOHNSON

JOHN E. CONERY JUDGE

Panel composed of John D. Saunders, James T. Genovese, and John E. Conery, Judges.

WRIT GRANTED AND MADE PEREMPTORY. Mark T. Garber Mark T. Garber, Attorney at Law, L.L.C. 2000 West Congress Lafayette, Louisiana 70506 (337) 234-5500

COUNSEL FOR RELATOR BETTY MOUTON

Michael E. Parker Allen & Gooch, A Law Corporation 2000 Kaliste Saloom Road, Suite 400 Lafayette, Louisiana 70508 (337) 291-1350

COUNSEL FOR RESPONDENT LAFAYETTE CARE CENTER CONERY, Judge.

The defendant-relator, Betty Mouton (Mouton), seeks supervisory writs

from the March 12, 2014 judgment of the Office of Workers’ Compensation,

District 4, Adam Johnson, presiding, which denied Mouton’s exception of no cause

of action. For the following reasons, we grant the writ and grant Mouton’s

exception of no cause of action dismissing the Form 1008, Disputed Claim for

Compensation, filed on January 28, 2013, by plaintiff-respondent, Lafayette Care

Center (LCC) at LCC’s cost.

FACTS AND PROCEDURAL HISTORY

Mouton allegedly injured her left knee on August 20, 2009, when she

slipped and fell in the course and scope of her employment as a Certified Nurse’s

Assistant (CNA) with LCC. Mouton has been paid indemnity and medical benefits

since the date of her injury. On January 28, 2013, LCC filed a Form 1008,

Disputed Claim for Compensation. The Form 1008 requested that Mouton specify

her work status, provide recommendations for future medical treatment, and

submit to a vocational rehabilitation examination.

At the time of Mouton’s injury in 2009, La.R.S. 23:1314 provided that any

claims initiated under La.R.S. 23:1310.3 would be considered premature unless the

claim met one of the four enumerated circumstances. Those circumstances

included an employer’s failure to pay the petitioner the maximum percentage of

wages; furnish or pay for medical treatment; furnish requested medical reports; or

pay penalties and attorney fees owed to the petitioner.

Also at the time of Mouton’s injury in 2009, La.R.S. 23:1310 allowed for an

employer to file a disputed claim after a death or injury with the state or district office relating to a benefit in dispute. See American Home Ins. Co. Unified

Recovery Grp., LLC v. Morrison, 13-1448 (La.App. 1 Cir. 4/28/14), ___So.3d.___.

In 2012, the Louisiana legislature, pursuant to Act 860, amended La.R.S.

23:1314, effective August 1, 2012, to include sections D and E, which provided:

D. Disputes over medical treatment pursuant to the medical treatment schedule shall be premature unless a decision of the medical director has been obtained in accordance with R.S. 23:1203.1(J).

E. Notwithstanding any other provisions of this Section, the employer shall be permitted to file a disputed claim to controvert benefits or concerning any other dispute arising under this Chapter.

(Emphasis added.)

Thus, the employer was able to go forward with a disputed claim based on

the 2012 amendment. However, the 2013 legislature again amended La.R.S.

23:1314(E), effective date of August 1, 2013, to further define the circumstances

under which an employer could file a disputed claim to only disputes involving

fraud or when the employer was appealing a decision of the medical director

pursuant to R.S. 23:1203.1(K).

The legislature specifically provided for prospective and retroactive

application of the 2013 amendment. “This Act is declared to be remedial, curative,

and procedural and therefore is to be applied retroactively as well as prospectively.

However, should any provision of this Act be declared to apply prospectively only,

all provisions of this Act shall be applied prospectively only.”

In response to the 2013 amendment to La.R.S. 23:1314 (E), Mouton filed an

exception of no cause of action, claiming the employer’s Form 1008, Disputed

Claim for Compensation was premature, as it failed to allege fraud or a dispute

involving the medical director’s recommendation.

2 The exception was heard before the workers’ compensation judge (WCJ) on

February 21, 2014. After the hearing, the WCJ took the matter under advisement

and on February 27, 2014, rendered written reasons on the record denying

Mouton’s exception of no cause of action. Judgment was signed on March 12,

2014. Mouton filed the instant writ, and the trial date of July 3, 2014, was stayed

by the trial court pending the final disposition of this matter.

SUPERVISORY RELIEF

“The exercise of supervisory jurisdiction by appellate courts is within their

plenary power. La. Const. art. 5, § 10. Appellate courts generally will not exercise

such jurisdiction unless an error in the trial court’s ruling will cause the petitioner

irreparable injury or an ordinary appeal does not afford an adequate remedy.”

Cook v. Family Cares Services, Inc., 13-108, p. 2 (La.App. 3 Cir. 8/28/13), 121

So.3d 1274, 1276. In such instances, “judicial efficiency and fundamental fairness

to the litigants dictates that the merits of the application for supervisory writs

should be decided in an attempt to avoid the waste of time and expense of a

possibly useless future trial on the merits.” Herlitz Const. Co., Inc. v. Hotel

Investors of New Iberia, Inc., 396 So.2d 878, (La.1981) (per curiam).

STANDARD OF REVIEW

The interpretation of a statute is a question of law, which is reviewed “under

a de novo standard of review” without deference to the lower court’s decision.

Caldwell v. Janssen Pharm., Inc., 12- 2447, p. 9 (La. 1/28/14), ___ So.3d ___, ___.

“The method for judicially interpreting statutory law, and determining whether it

applies to a specific set of facts, is well-settled in our jurisprudence. The essential

question in all cases of statutory interpretation is legislative intent and the

ascertainment of the reason or reasons that prompted the legislature to enact the

3 law.” Id. at 10. “It is a fundamental principle of statutory interpretation that

‘[w]hen a law is clear and unambiguous and its application does not lead to absurd

consequences, the law shall be applied as written, and no further interpretation may

be made in search of the intent of the legislature.’ La. Civ.Code art. 9 (2004).” Id.

DISCUSSION

“The function of an exception of no cause of action is to test the legal

sufficiency of the petition by determining whether the law affords a remedy on the

facts alleged in the pleading.” Everything on Wheels Subaru, Inc. v. Subaru S.,

Inc., 616 So.2d 1234, 1235 (La.1993).

In the WCJ’s written reasons for ruling on Mouton’s exception of no cause

of action concerning the application of both the 2012 amendment and the 2013

amendment to La.R.S. 23:1314, the WCJ stated:

This matter came before the Court pursuant to an Exception of No Cause of Action. The Court has reviewed the 2012 amendment to 1314, and it reads: Necessary Allegations, Dismissal of Premature Petition, Dispute of Benefits. Further down, (e) states:

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Related

Sawicki v. K/S STAVANGER PRINCE
802 So. 2d 598 (Supreme Court of Louisiana, 2001)
Everything on Wheels Subaru, Inc. v. Subaru South, Inc.
616 So. 2d 1234 (Supreme Court of Louisiana, 1993)
Herlitz Const. Co., Inc. v. Hotel Investors of New Iberia, Inc.
396 So. 2d 878 (Supreme Court of Louisiana, 1981)
Cook v. Family Care Services, Inc.
121 So. 3d 1274 (Louisiana Court of Appeal, 2013)
Times-Picayune Publishing Co. v. Jacobs
126 So. 741 (Louisiana Court of Appeal, 1930)

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Lafayette Care Center v. Betty Mouton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lafayette-care-center-v-betty-mouton-lactapp-2014.