Mary Elizabeth Madden Chumley, E. Gary Chumley, and Madden Property Management, LLC v. Donna Lacour

CourtLouisiana Court of Appeal
DecidedMay 25, 2022
Docket54,499-CA
StatusPublished

This text of Mary Elizabeth Madden Chumley, E. Gary Chumley, and Madden Property Management, LLC v. Donna Lacour (Mary Elizabeth Madden Chumley, E. Gary Chumley, and Madden Property Management, LLC v. Donna Lacour) 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
Mary Elizabeth Madden Chumley, E. Gary Chumley, and Madden Property Management, LLC v. Donna Lacour, (La. Ct. App. 2022).

Opinion

Judgment rendered May 25, 2022. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 54,499-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

MARY ELIZABETH MADDEN Plaintiffs-Appellants CHUMLEY, E. GARY CHUMLEY, AND MADDEN PROPERTY MANAGEMENT, LLC

versus

DONNA LACOUR Defendant-Appellee

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 626595

Honorable Ramon Lafitte, Judge

ALAN PESNELL LAWYER, LLC Counsel for Appellants By: W. Alan Pesnell

KEVIN W. HAMMOND, APLC Counsel for Appellee By: Kevin W. Hammond

J. SCHUYLER MARVIN Counsel for Intervenors/Appellees, James D. Madden and Lyda Roberts Madden

Before STEPHENS, ROBINSON, and HUNTER, JJ. HUNTER, J.

The plaintiffs, Mary Madden Chumley, E. Gary Chumley and Madden

Property Management, LLC, appeal a judgment sustaining the exception of

lis pendens of defendant, Donna LaCour. The trial court dismissed the

plaintiffs’ action without prejudice. In sustaining the exception, the trial

court found a ruling on the petition of intervention filed by James and Lyda

Madden was pretermitted as moot. For the following reasons, we affirm.

FACTS

Madden Property Management, LLC (“MPM”), is a Louisiana limited

liability company domiciled in Caddo Parish. Johnye Mae Madden was the

sole owner of MPM until 2002, when her daughter, Mary Madden Chumley

(“Chumley”), became a co-owner. On January 26, 2016, Johnye Mae

Madden (“decedent”) died in Webster Parish. Subsequently, a petition for

probate of a notarial testament was filed and the Succession of the Johnye

Mae Madden estate was opened in Webster Parish. Chumley served as

executrix of the succession until May 2019, when she was removed by the

trial court, which appointed Donna LaCour as executrix. The removal was

affirmed on appeal. Succession of Madden, 53,353 (La. App. 2 Cir. 3/4/20),

293 So. 3d 665.

While serving as executrix, LaCour noted decedent’s interest in MPM

was not listed as an asset of the estate, despite being mentioned in her will.

LaCour then issued a subpoena to Chumley and MPM seeking MPM’s

organizational and banking records. Chumley opposed the subpoena and

objected to the authority of the executrix to obtain those records. Chumley

was eventually ordered to produce the records of MPM and was later

sanctioned for failing to produce the requested records. In denying Chumley’s writ seeking review of the sanctions, a concurring justice of the

Louisiana Supreme Court noted Chumley had been held in contempt for

refusing to produce records “to support her longstanding assertion in these

proceedings that she is entitled to a higher ownership percentage” of MPM.

In re Succession of Madden, 2021-00645 (La. 9/27/21), 324 So. 3d 86.

In October 2020, the plaintiffs, Mary Madden Chumley, E. Gary

Chumley and MPM, filed a petition in the district court of Caddo Parish

against defendant, Donna LaCour, as executrix of decedent’s succession,

seeking a judgment to declare the ownership of MPM. The defendant,

Donna LaCour (“LaCour”), in her capacity as executrix for decedent’s

estate, filed an exception of lis pendens alleging the issue of the ownership

of MPM was already being litigated in the decedent’s succession

proceedings in Webster Parish when plaintiffs filed their petition. The

plaintiffs opposed the exception.

In March 2021, a petition of intervention was filed by James and Lyda

Madden, who alleged exceptions of no right of action and improper venue to

plaintiffs’ lawsuit. In June 2021, defendant filed in the succession

proceeding an amended detailed descriptive list of assets and liabilities

asserting the estate’s interest in MPM.

After a hearing, the trial court sustained the exception of lis pendens,

finding that the ownership of MPM was an issue in the earlier filed

succession and should be determined in that proceeding in Webster Parish.

Based on this ruling, the trial court found the petition and exceptions of the

intervenors were moot. The trial court rendered judgment sustaining the

exception of lis pendens and dismissing plaintiffs’ petition without

prejudice. Plaintiffs appeal the judgment. 2 DISCUSSION

The plaintiffs contend the trial court erred in granting the exception of

lis pendens. Plaintiffs argue the requirements of lis pendens are not present

because no suit was filed in Webster Parish, and the succession does not

involve the same transaction or occurrence, or the same parties, as this

action.

When two or more suits are pending in Louisiana courts on the same

transaction or occurrence, between the same parties in the same capacities,

the defendant may have all but the first suit dismissed by excepting thereto.

La. C.C.P. art. 531. A civil action is the demand for the enforcement of a

legal right commenced by the filing of a pleading presenting the demand to a

court of competent jurisdiction. La. C.C.P. art. 421. A pleading includes a

petition, exception, written motion and answer. La. C.C.P. art. 852.

The plaintiffs assert in their brief there was no “suit” pending in

Webster Parish when they filed the present action. However, we note that

although Article 531 uses the term suit, the Louisiana Code of Civil

Procedure refers to a “civil action” as the beginning of a legal proceeding.

Under Article 421, a civil action commences when a petition is filed in a

court of competent jurisdiction. After a civil action commences, it is

pending under Article 531 for the purposes of lis pendens. Sims v. Sims, 247

So. 2d 602 (La. App. 3 Cir. 1971).

The record shows in March 2016, a petition for the probate of a

notarial testament was filed in district court in Webster Parish and the

Succession of Johnye Mae Madden was opened. Thus, when plaintiffs filed

this action, the succession was a civil action, or suit, pending in Webster

3 Parish for the purposes of lis pendens. Consequently, the plaintiffs’

assertion that no other action was pending lacks merit.

Plaintiffs contend the two actions do not involve the same transaction

or occurrence. Defendant argues ownership of MPM was at issue in the

succession before plaintiffs’ action was filed.

The test for deciding whether an exception of lis pendens should be

granted is whether a final judgment in the first suit would be res judicata in

the subsequently filed suit. To determine if the subject matter of the two

lawsuits is the same for res judicata, a court examines the factual basis of the

claim in the prior litigation, regardless of the form of that action. Brooks

Well Servicing, Inc. v. Cudd Pressure Control, Inc., 36,723 (La. App. 2 Cir.

6/27/03), 850 So. 2d 1027.

In this case, the record shows that when the succession executrix

issued subpoenas to obtain business records of MPM to support the estate’s

claim of an ownership interest in the limited liability company, Chumley

opposed the estate’s records request by asserting her ownership of MPM in

Webster Parish. Plaintiffs then filed the present action in Caddo Parish

asserting the same claim of Chumley’s ownership of MPM.

In addition, this court considers the issue of lis pendens in the

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Related

Forum for Equality PAC v. McKeithen
893 So. 2d 738 (Supreme Court of Louisiana, 2005)
Sims v. Sims
247 So. 2d 602 (Louisiana Court of Appeal, 1971)
BROOKS WELL SERV. v. Cudd Pressure Control
850 So. 2d 1027 (Louisiana Court of Appeal, 2003)

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Mary Elizabeth Madden Chumley, E. Gary Chumley, and Madden Property Management, LLC v. Donna Lacour, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mary-elizabeth-madden-chumley-e-gary-chumley-and-madden-property-lactapp-2022.