Mickey McGuinness Quinlan, Mackey Sugar Quinlan, and Charles Brian Sugar v. Melissa Sugar-Gold

CourtLouisiana Court of Appeal
DecidedMarch 11, 2020
Docket53,348-CA
StatusPublished

This text of Mickey McGuinness Quinlan, Mackey Sugar Quinlan, and Charles Brian Sugar v. Melissa Sugar-Gold (Mickey McGuinness Quinlan, Mackey Sugar Quinlan, and Charles Brian Sugar v. Melissa Sugar-Gold) 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
Mickey McGuinness Quinlan, Mackey Sugar Quinlan, and Charles Brian Sugar v. Melissa Sugar-Gold, (La. Ct. App. 2020).

Opinion

Judgment rendered March 11, 2020. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 53,348-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

MICKEY McGUINNESS Plaintiffs- 2nd Appellants QUINLAN, MACKEY SUGAR QUINLAN, AND CHARLES BRIAN SUGAR

versus MELISSA SUGAR-GOLD Defendant-1st Appellant

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 574,162

Honorable Craig Owen Marcotte, Judge

THE PESNELL LAW FIRM, APLC Counsel for 1st Appellant, By: Billy Ray Pesnell Melissa Sugar-Gold John Whitney Pesnell

McMICHAEL, MEDLIN, D’ANNA Counsel for 2nd Appellants, By: James C. McMichael, Jr. Mickey McGuinness Quinlan, Elizabeth E. Wong Mackey Sugar Quinlan, and Charles Brian Sugar

Before WILLIAMS, STEPHENS, and McCALLUM, JJ. STEPHENS, J.

Defendant, Melissa Sugar-Gold, and plaintiffs, Mickey McGuiness

Quinlan, Mackey Sugar Quinlan, and Charles Brian Sugar, appeal a

judgment of the First Judicial District Court, Parish of Caddo, State of

Louisiana, awarding defendant attorney fees in connection with her special

motion to strike wherein she prevailed against plaintiffs. For the following

reasons, we affirm in part and reverse in part the trial court’s judgment.

FACTS AND PROCEDURAL HISTORY

This matter arises from plaintiffs’ petition for injunctive relief and

damages for defamation and intentional infliction of emotional distress filed

against defendant in January 2014. The underlying facts of the action are

discussed in this court’s previous opinion, Quinlan v. Sugar-Gold, 51,191

(La. App. 2 Cir. 4/5/17), 219 So. 3d 1173 (“Quinlan I”). In response to

plaintiffs’ petition, defendant filed peremptory exceptions of no cause of

action and prescription as well as a special motion to strike plaintiffs’

petition, pursuant to La. C.C.P. art. 971. The trial court granted defendant’s

special motion to strike and dismissed plaintiffs’ petition with prejudice.

However, the trial court denied defendant’s request for attorney fees and

ordered the parties to bear their own costs. Defendant filed a motion for new

trial, arguing an award of attorney fees and costs was mandated under La.

C.C.P. 971(B); the trial court denied this. Both parties appealed the trial

court’s judgment. In Quinlan I, this court affirmed the trial court’s ruling

granting defendant’s special motion to strike and reversed the trial court’s

ruling denying attorney fees. The matter was remanded to the trial court.

The trial court subsequently held a hearing on March 4, 2019, wherein

defendant put on evidence in support of her claim for a total of $109,275 in attorney fees and costs. The trial court issued a written opinion on May 29,

2019, and judgment was thereafter filed on June 13, 2019, awarding

defendant $48,588.33 in attorney fees and costs in connection with her

special motion to strike and denying her claim for attorney fees in

connection with her prior appeal, exceptions of no cause of action and

prescription, and motion for new trial.1 Both parties appeal the trial court’s

judgment.

DISCUSSION

Legal Principles

Louisiana C.C.P. art. 971 provides, in pertinent part:

A. (1) A cause of action against a person arising from any act of that person in furtherance of the person’s right of petition or free speech under the United States or Louisiana Constitution in connection with a public issue shall be subject to a special motion to strike, unless the court determines that the plaintiff has established a probability of success on the claim.

(2) In making its determination, the court shall consider the pleadings and supporting and opposing affidavits stating the facts upon which the liability or defense is based.

...

B. In any action subject to Paragraph A of this Article, a prevailing party on a special motion to strike shall be awarded reasonable attorney fees and costs.

Article 971 was enacted by the legislature as a procedural device to be used

in the early stages of litigation to screen out meritless claims brought

primarily to chill the valid exercise of the constitutional rights of freedom of

speech and petition for redress of grievances. Johnson v. KTBS, Inc., 39,022

(La. App. 2d Cir. 11/23/04), 889 So. 2d 329, writ denied, 2004-3192 (La.

1 The trial court’s judgment does not expressly mention defendant’s motion for new trial, but its opinion makes clear it did not award any attorney fees in connection with that motion.

2 3/11/05), 896 So. 2d 68. In the act that created art. 971 (1999 La. Acts No.

734, § 2), the legislature stated its intent in enacting the provision as follows:

Section 2. The legislature finds and declares that there has been a disturbing increase in lawsuits brought primarily to chill the valid exercise of the constitutional rights of freedom of speech and petition for redress of grievances. The legislature finds and declares that it is in the public interest to encourage continued participation in matters of public significance, and that this participation should not be chilled through abuse of the judicial process. To this end, it is the intention of the legislature that the Article enacted pursuant to this Act shall be construed broadly.

In any action subject to La. C.C.P. art. 971(A), a prevailing party on a

special motion to strike shall be awarded reasonable attorney fees and costs.

La. C.C.P. art. 971(B); In re Succession of Carroll, 46,327 (La. App. 2 Cir.

7/20/11), 72 So. 3d 384, writ not cons., 2011-1844 (La. 11/4/11), 75 So. 3d

912. As a general rule, attorney fees are not allowed in Louisiana unless

they are authorized by statute or provided for by contract. State, Dept. of

Transp. & Dev. v. Wagner, 2010-0050 (La. 5/28/10), 38 So. 3d 240; Carroll

Insulation & Window Co., Inc. v. Biomax Spray Foam Insulation, LLC,

50,112 (La. App. 2d Cir. 11/18/15), 180 So. 3d 518. Statutes providing for

penalties and/or attorney fees are penal in nature and must be strictly

construed. See Langley v. Petro Star Corp. of La., 2001-0198 (La. 6/29/01),

792 So. 2d 721; Jones v. Johnson, 45,847 (La. App. 2d Cir. 12/15/10), 56

So. 3d 1016. An award of attorney fees is a type of penalty imposed, not to

make the injured party whole, but rather to discourage a particular activity

on the part of the opposing party. Langley, supra; Sharbono v. Steve Lang &

Son Loggers, 1997-0110 (La. 7/1/97), 696 So. 2d 1382. In the context of the

special motion to strike, the trial court’s award of attorney fees is subject to

the deferential abuse of discretion standard of review. See Davis v. Benton,

3 03-0851 (La. App. 1 Cir. 2/23/04), 874 So. 2d 185 (finding “no abuse of

discretion” in the trial court’s award of attorney fees).

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Mickey McGuinness Quinlan, Mackey Sugar Quinlan, and Charles Brian Sugar v. Melissa Sugar-Gold, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mickey-mcguinness-quinlan-mackey-sugar-quinlan-and-charles-brian-sugar-v-lactapp-2020.