Michael A. Couvillion in His Capacity as Sheriff of Vermilion Parish v. Nationwide Agribusiness Insurance Company

CourtLouisiana Court of Appeal
DecidedMarch 6, 2024
DocketCA-0023-0489
StatusUnknown

This text of Michael A. Couvillion in His Capacity as Sheriff of Vermilion Parish v. Nationwide Agribusiness Insurance Company (Michael A. Couvillion in His Capacity as Sheriff of Vermilion Parish v. Nationwide Agribusiness Insurance Company) 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
Michael A. Couvillion in His Capacity as Sheriff of Vermilion Parish v. Nationwide Agribusiness Insurance Company, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

23-488

CHARLES LEVINE

VERSUS

NATIONWIDE AGRIBUSINESS INSURANCE COMPANY, ET AL.

Consolidated with

23-489

MICHAEL A. COUVILLION, IN HIS CAPACITY AS SHERIFF OF VERMILION PARISH, ET AL.

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF VERMILION, NO. 107,696 (consolidated with 107,785) HONORABLE MICHELLE M. BREAUX, DISTRICT JUDGE

CHARLES G. FITZGERALD JUDGE

Court composed of Elizabeth A. Pickett, Charles G. Fitzgerald, and Wilbur L. Stiles, Judges.

REVERSED IN PART; AFFIRMED AS AMENDED. Jason M. Welborn Jacob H. Hargett Welborn and Hargett, LLC 1540 W. Pinhook Road Lafayette, Louisiana 70503 Phone: (337) 234-5533 Fax: (337) 769-3173 Counsel for Plaintiff: Charles Levine

Isaac H. Ryan Ike Ryan APLC 1100 Poydras Street, Suite 2905 New Orleans, Louisiana 70163 Phone: (504) 952-0505 Counsel for Defendants: Berkshire Hathaway Specialty Insurance Company Universal Environmental Services, LLC Renauldo Hawkins

Emily E. Eagan 701 Poydras Street, Suite 4800 New Orleans, Louisiana 70139 Phone: (504) 561-0400 Fax: (504) 561-1011 Counsel for Defendant: Berkshire Hataway Specialty Insurance Company

Joshua Trahan 102 Versailles Boulevard, Suite 400 Lafayette, Louisiana 70509 Phone: (337) 237-6062 Fax: (337) 237-9129 Counsel for Defendant: Universal Environmental Services, LLC

Ney Gehman Kimberly G. Anderson 3850 North Causeway Boulevard, Suite 1230 Metairie, Louisiana 70002 Phone: (504) 837-9017 Fax: (855) 810-2532 Counsel for Defendants: Renauldo Hawkins Universal Environmental Services, LLC Nationwide Agribusiness Insurance Company FITZGERALD, Judge.

In this appeal, we are asked to review the jury’s allocation of fault and award

of damages.

SUMMARY OF FACTS AND PROCEDURAL HISTORY

This lawsuit arises from a motor vehicle accident. The relevant facts are not

in dispute.

In January 2019, Renauldo Hawkins became distracted while driving a large

box truck down U.S. Highway 167 in Vermilion Parish, Louisiana. The box truck

was owned by Renauldo’s employer, Universal Environmental Services (UES). By

all accounts, Renauldo bent down to retrieve a bottle of water while traveling at

approximately sixty-five miles per hour and smashed into the back of a Vermilion

Parish Sheriff’s Office police cruiser being driven by Deputy Sheriff Charles Levine.

As a result of the collision, the deputy sheriff suffered serious personal injuries.

In December 2020, Deputy Sheriff Levine filed a damages suit against

Renauldo, UES, and UES’s primary insurer, Nationwide Agribusiness Insurance

Company, alleging negligent acts by Renauldo. In February 2022, Plaintiff filed a

first amended petition for damages. The amended petition added UES’s excess

insurer, Berkshire Hathaway Specialty Insurance Company, as a defendant. The

amended petition also asserted direct negligence claims against UES, including

negligent hiring, negligent training, and negligent supervision. A jury trial was fixed

for September 2022.

It is undisputed that the accident occurred while Renauldo was acting within

the course and scope of his employment with UES and that UES is vicariously liable

for any damages resulting from Renauldo’s negligence. In fact, fourteen days before

trial, all Defendants collectively filed a document styled “Defendants’ Binding and Irrevocable Judicial Admissions and Judicial Confessions Regarding Liability” in

which they confessed that Renauldo is 100% at fault for causing the accident and

that UES is vicariously liable for Renauldo’s negligence. In that document,

Defendants reserved only their right to contest medical causation and damages.

A five-day jury trial began on September 26, 2022. The jury, in turn, awarded

Plaintiff damages in the amount of $5,000,000.00. On November 15, 2022, the trial

court signed a final judgment which reduced the award to $3,500,000.00. Two days

later, Plaintiff moved for a judgment notwithstanding the verdict and for a new trial

on the issue of liability. Both motions were denied by the trial court on February 27,

2023.

Plaintiff now appeals the original judgment and the judgment denying his

post-trial motions, asserting five assignments of error:

1. The Trial Court committed reversible legal error, by failing to grant a new trial based on the Defendants’ intentional act to conceal discoverable documents ordered to be produced by the trial court, which were discovered after the trial.

2. The Trial Court committed reversible legal error, by placing First Advantage on the verdict form, and allowing Defendants to argue First Advantage’s fault in closing arguments, given the Defendants’ stipulation of Liability prior to trial.

3. The Trial Court committed reversible legal error, by failing to prohibit First Advantage from being placed on the verdict form given the Defendants’ failure to properly prove any contractual duty and given the Defendant’s non-delegable duty to comply with the FMCSR.

4. The Trial Court committed reversible legal error, by failing to grant Plaintiff’s judgment notwithstanding the verdict (“JNOV”) or in the alternative a New Trial on the issue of liability for three reasons.

5. The Trial Court committed reversible legal error, by applying its own interpretation of the jury’s verdict to the percentage of court costs owed to the plaintiff.

2 In response, Defendants answered the appeal, asserting two assignments of

error:

1. The jury’s $3,231,941.87 award for general damages is grossly excessive.

2. The district court erroneously prohibited defendants from adducing evidence that $318,756.72 of Mr. Levine’s claimed medical expenses were “phantom charges” that neither Mr. Levine nor anyone else would ever be expected to pay.

LAW AND ANALYSIS

In the discussion that follows, we begin by reviewing Plaintiff’s second

assignment of error. Next, we address Plaintiff’s third, fourth, and fifth assignments

of error. However, because Plaintiff’s first and fourth assignments seek review of

the same thing—the denial of Plaintiff’s post-trial motions—those assignments are

discussed together. Thereafter, we turn our attention to Defendants’ first and second

assignments of error.

Plaintiff’s Second Assignment of Error

Here, Plaintiff argues the trial court committed reversible legal error by adding

First Advantage (a nonparty potential joint tortfeasor) to the jury verdict form and

by allowing Defendants to raise the issue of First Advantage’s fault during closing

arguments. Plaintiff contends that “Defendants’ Binding and Irrevocable Judicial

Admissions and Judicial Confessions Regarding Liability” precluded UES from

shifting liability to First Advantage. We agree.

Louisiana Civil Code Article 1853 addresses judicial confessions: “A judicial

confession is a declaration made by a party in a judicial proceeding. That confession

constitutes full proof against the party who made it. A judicial confession is

indivisible and it may be revoked only on the ground of error of fact.”

3 In C.T. Traina, Inc. v. Sunshine Plaza, Inc., 03-1003, p. 5 (La. 12/3/03), 861

So.2d. 156, 159, the Louisiana Supreme Court explained that a judicial confession

“has the effect of waiving evidence as to the subject of the admission.” This court

further specified that a party cannot contest a fact or issue if he has judicially

admitted it during the proceedings. Leprettre v. RCS, LLC, 16-382 (La.App. 3 Cir.

11/16/16), 206 So.3d 1215.

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Michael A. Couvillion in His Capacity as Sheriff of Vermilion Parish v. Nationwide Agribusiness Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-a-couvillion-in-his-capacity-as-sheriff-of-vermilion-parish-v-lactapp-2024.