Osceola P. Scanlan and Samuel P. Scanlan Versus Mbf of Metairie, LLC D/B/A Matt Bowers Ford, Christopher Haggstrom, Jeffrey Burns, Christopher Jac, and Ab Insurance Company

CourtLouisiana Court of Appeal
DecidedMarch 23, 2022
Docket21-CA-323
StatusUnknown

This text of Osceola P. Scanlan and Samuel P. Scanlan Versus Mbf of Metairie, LLC D/B/A Matt Bowers Ford, Christopher Haggstrom, Jeffrey Burns, Christopher Jac, and Ab Insurance Company (Osceola P. Scanlan and Samuel P. Scanlan Versus Mbf of Metairie, LLC D/B/A Matt Bowers Ford, Christopher Haggstrom, Jeffrey Burns, Christopher Jac, and Ab 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.

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Osceola P. Scanlan and Samuel P. Scanlan Versus Mbf of Metairie, LLC D/B/A Matt Bowers Ford, Christopher Haggstrom, Jeffrey Burns, Christopher Jac, and Ab Insurance Company, (La. Ct. App. 2022).

Opinion

OSCEOLA P. SCANLAN AND SAMUEL P. NO. 21-CA-323 SCANLAN FIFTH CIRCUIT VERSUS COURT OF APPEAL MBF OF METAIRIE, LLC D/B/A MATT BOWERS FORD, CHRISTOPHER STATE OF LOUISIANA HAGGSTROM, JEFFREY BURNS, CHRISTOPHER JAC, AND AB INSURANCE COMPANY

ON APPEAL FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT PARISH OF JEFFERSON, STATE OF LOUISIANA NO. 809-296, DIVISION "K" HONORABLE ELLEN SHIRER KOVACH, JUDGE PRESIDING

March 23, 2022

MARC E. JOHNSON JUDGE

Panel composed of Judges Susan M. Chehardy, Marc E. Johnson, and Hans J. Liljeberg

AFFIRMED IN PART; REVERSED IN PART; REMANDED WITH INSTRUCTIONS MEJ SMC HJL COUNSEL FOR PLAINTIFF/APPELLANT, OSCEOLA P. SCANLAN AND SAMUEL P. SCANLAN Raymond C. Burkart, Jr. JOHNSON, J.

Plaintiffs/Appellants, Osceola P. Scanlan and Samuel P. Scanlan, appeal the

trial court’s judgment that sustained the peremptory exception of

Defendants/Appellees, MBF of Metairie, LLC d/b/a Matt Bowers Ford (hereinafter

referred to as “MBF”), Christopher Haggstrom, Jeffery Burns, and Christopher

Jackson, and dismissed the action of Samuel, without prejudice, for loss of wages

in the 24th Judicial District Court, Division “K”. For the following reasons, we

affirm in part, reverse in part, and remand to the trial court with instructions.

FACTS AND PROCEDURAL HISTORY

On August 17, 2020, Appellants filed a “Petition for Damages” against

Defendants. In their joint petition, Appellants alleged that on or about September

3, 2019, Samuel was changing the spark plugs on a 2006 Ford Mustang owned by

his father, Osceola. While changing the spark plugs, a piece of a spark plug broke

off and fell into cylinder head number five, which subsequently required the

service repair of the Mustang by Appellees. Appellants alleged that they incurred

damages through the negligence and breach of duties of Appellees during the

service repair of the Mustang. Specifically, Samuel alleged a loss of wages.

Appellees filed their “Exception of No Cause of Action with Incorporated

Memorandum in Support, Answer to Petition for Damages, and Reconventional

Demand” on October 26, 2020. In their exception, Appellees asserted that Samuel

had no ownership and/or insurable interest in the Mustang; thus, they could not be

liable to Samuel for any damages under any legal theory. Appellees then alleged

in their reconventional demand that the damages claimed by Appellants were

caused solely by the fault and/or negligence of Samuel and requested judgment

against Samuel for any amount that may be rendered against them.

A hearing on the exception of no cause of action was held on January 8,

2021. At the conclusion of the hearing, the trial court sustained Appellees’

21-CA-323 1 exception and dismissed Samuel’s claims against them without prejudice. The trial

court rendered a written judgment stating the same on February 19, 2021.

Appellants filed a motion for new trial on January 25, 2021, which was denied by

the trial court on March 22, 2021. The instant appeal followed.

ASSIGNMENTS OF ERROR

On appeal, Appellants alleged that the trial court committed reversible error

by: 1) dismissing Samuel’s claims against Appellees, and 2) denying their motion

for a new trial.

LAW AND ANALYSIS

Dismissal of Samuel’s claims and Denial of Motion for New Trial1

Appellants have raised the denial of their motion for new trial as an

assignment of error. Denial of a motion for new trial is an interlocutory and non-

appealable judgment. First Bank and Trust v. Proctor’s Cove II, LLC, 13-802 (La.

App. 5 Cir. 9/24/14); 150 So.3d 418, 423, writ denied, 14-2236 (La. 1/9/15); 157

So.3d 1110. However, the Louisiana Supreme Court has instructed the courts of

appeal to consider an appeal of the denial of a motion for new trial as an appeal of

the judgment on the merits, when it is clear from the appellant’s brief that the

intent is to appeal the merits of the case. Id. It is clear from Appellants’ brief that

they intended to appeal the merits of the February 19, 2021 judgment, which

sustained Appellees’ exception of no cause of action and dismissed Samuel’s

claims against them.

Appellants allege that the trial court erred in sustaining Appellee’s

peremptory exception of no cause of action and dismissing Samuel’s claims. They

argue that Samuel states a cause of action in the joint petition. They contend that

Samuel had usufruct of the Mustang because Osceola gave Samuel use and

possession of the Mustang for a limited period of time to derive income from

1 Appellees did not file a brief in this appeal.

21-CA-323 2 Samuel’s gainful employment; and, as a usufructuary, Samuel had the right to

possess the Mustang and derive the utility, profits, and advantages that possession

of the Mustang produced. Thus, Appellants maintain that Samuel had an insurable

interest in the Mustang through his usufruct.

Appellants also argue that they had a gratuitous contract, whereby Osceola

loaned a non-consumable thing (the Mustang) to Sam for his use and return. They

contend that their gratuitous contract is akin to the rights of a lessee who sustains

damages. Appellants further argue that Appellees’ reconventional demand is an

additional acknowledgment of the existence of Samuel’s cause of action. Lastly,

Appellants argue that Samuel’s petition raises causes of action, subject to the duty-

risk analysis. In the event that this Court does not overrule the trial court’s

judgment, Appellants request that they be allowed to amend Samuel’s petition for

damages.

Pursuant to La. C.C.P. art. 934, “[w]hen the grounds of the objection

pleaded by the peremptory exception may be removed by amendment of the

petition, the judgment sustaining the exception shall order such amendment within

the delay allowed by the court. If the grounds of the objection raised through the

exception cannot be so removed, or if the plaintiff fails to comply with the order to

amend, the action, claim, demand, issue, or theory shall be dismissed.” When

reviewing a judgment sustaining a peremptory exception of no cause of action, this

Court, in Grubbs v. Haven Custom Furnishings, LLC, 18-710 (La. App. 5 Cir.

5/29/19); 274 So.3d 844, 847-48, has stated the following:

A cause of action, for purposes of the peremptory exception, is defined as the operative facts that give rise to the plaintiff’s right to judicially assert an action against the defendant. The function of the peremptory exception of no cause of action is to question whether the law extends a remedy to anyone under the factual allegations of the petition. The exception’s function is to test the legal sufficiency of the petition by determining whether the law affords a remedy on the facts alleged in the pleading. No evidence may be introduced to support or controvert the exception raising the objection of no cause

21-CA-323 3 of action. For the purpose of determining the issues raised by the exception, all facts pleaded in the petition must be accepted as true.

The appellate court standard of review of a judgment sustaining an exception of no cause of action is de novo because the exception raises a question of law, and the trial court’s decision is based only on the sufficiency of the petition. A petition should not be dismissed for failure to state a cause of action, unless it appears beyond a doubt the plaintiff can prove no set of facts in support of any claim that would entitle him to relief.

(Internal citations omitted).

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Related

First Bank & Trust v. Proctor's Cove II, LLC
150 So. 3d 418 (Louisiana Court of Appeal, 2014)
In re Griffin
249 So. 3d 1048 (Louisiana Court of Appeal, 2018)

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Osceola P. Scanlan and Samuel P. Scanlan Versus Mbf of Metairie, LLC D/B/A Matt Bowers Ford, Christopher Haggstrom, Jeffrey Burns, Christopher Jac, and Ab Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/osceola-p-scanlan-and-samuel-p-scanlan-versus-mbf-of-metairie-llc-dba-lactapp-2022.