Patrick Cummins v. R.A.H. Homes, LLC

CourtLouisiana Court of Appeal
DecidedMay 2, 2018
DocketCA-0017-0905
StatusUnknown

This text of Patrick Cummins v. R.A.H. Homes, LLC (Patrick Cummins v. R.A.H. Homes, LLC) 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
Patrick Cummins v. R.A.H. Homes, LLC, (La. Ct. App. 2018).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

17-905

PATRICK CUMMINS

VERSUS

R.A.H. HOMES, LLC, ET AL.

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. C-2016-4264 HONORABLE KRISTIAN EARLES, DISTRICT JUDGE

JOHN D. SAUNDERS JUDGE

Court composed of John D. Saunders, Elizabeth A. Pickett, and Shannon J. Gremillion, Judges.

AFFIRMED. Cle’ Simon Simon Law Offices P. O. Box 52242 Lafayette, LA 70505 (337) 232-2000 COUNSEL FOR PLAINTIFF/APPELLANT: Patrick Cummins

Keely Y. Scott Leigh F. Groves Kaitlin J. Dyer Donohue, Patrick & Scott, PLLC 450 Laurel Street, Suite 1600 Baton Rouge, LA 70801 (225) 214-1908 COUNSEL FOR DEFENDANT/APPELLEE: United Specialty Insurance Company R.A.H. Homes, L.L.C.

Timothy W. Hassinger Galloway, Johnson, Tompkins, Burr & Smith 3 Sanctuary Boulevard, 3rd Floor Mandeville, LA 70471 (985) 674-6680 COUNSEL FOR DEFENDANT/APPELLEE: Seneca Specialty Insurance Company

J. Quentin Simon J. Minos Simon, LTD P. O. Box 52851 Lafayette, LA 70505 (337) 235-3200 COUNSEL FOR PLAINTIFF/APPELLANT: Patrick Cummins

Phillip E. Foco Bienvenu, Bonnecaze, Foco, Viator & Holinga, APLLC 4210 Bluebonnet Boulevard Baton Rouge, LA 70809 (225) 388-5600 COUNSEL FOR DEFENDANT/APPELLEE: Stonetrust Commercial Insurance Company John Wayne Laurents In Proper Person 513 Herbert Road Lafayette, La 70506 (337) 212-6121 COUNSEL FOR DEFENDANT/APPELLEE: John Wayne Laurents SAUNDERS, Judge.

This is a Workers Compensation case in which we must decide whether the

Defendant/Principal is entitled to tort immunity under the two-contract theory as

provided in La.R.S. 23:1061(A)(2). Defendant entered into a contract with

homeowners to build a single-family residence, which contemplated or included

the installation of an HVAC system in the attic of the residence. Defendant

subcontracted the installation of the HVAC system. Subcontractor hired Plaintiff

as a laborer to fulfill its contract with Defendant. Plaintiff was injured while

performing the tasks required by Defendant’s contract with the Homeowners. As a

result, Plaintiff sued several defendants, including this Defendant in tort.

Defendant filed responsive pleadings generally denying the claims and

allegations of Plaintiff and asserting various affirmative defenses, including the

defense of statutory employer immunity.

After written discovery was exchanged between the parties, Defendant filed

a Motion for Summary Judgment requesting that Plaintiff’s claims against it be

dismissed. The trial court granted Defendant’s motion and dismissed Plaintiff’s

claim with prejudice.

Plaintiff now appeals the trial court’s ruling. His argument is that there are

genuine issue of material fact as to whether Defendant is a statutory employer and

as such, immune from tort liability.

FACTS AND PROCEDURAL HISTORY:

In August 2013, Paul and Nicole Stutes (“Homeowners”) hired Defendant,

R.A.H. Homes and Construction, LLC, (“R.A.H.”), to build a single-family

residence which contemplated or included the installation of an HVAC system in

the attic of the residence. R.A.H. hired John Wayne Laurents, d/b/a John Wayne

Construction (“Laurents”), to install the attic door at the residence. R.A.H. also entered into a subcontract agreement with United Mechanical Contractors, LLC

(“United”) to install the (“HVAC”) system. To fulfill its contract with R.A.H.,

United hired Plaintiff, Patrick Cummins (“Cummins”). While performing the tasks

required by R.A.H.’s contract with the Homeowners, Cummins was descending the

attic access ladder when the frame and ladder separated from the attic opening,

causing him to fall to the floor, resulting in serious injuries.

Cummins sued R.A.H., its insurer, United, and others. Cummins alleges that

R.A.H. and its employees are directly responsible for the improper installation of

the attic ladder which created an unreasonably dangerous condition; that R.A.H.

and its employees knew or should have known that the screws used to secure the

ladder assembly to the cased opening were inadequate to support the ladder

assembly; that the improperly installed ladder assembly caused Cummins to fall to

the ground and sustain serious injuries; and that R.A.H. is liable in tort to Cummins.

R.A.H. filed a Motion for Summary Judgment based on its affirmative

defense of statutory employer immunity under La.R.S. 23:1032 and 23:1061.

R.A.H. also filed a memorandum in support of its Motion for Summary Judgment.

Cummins filed an opposition to R.A.H.’s Motion for Summary Judgment.

Cummins also filed a sur-reply to R.A.H.’s memorandum in support of its Motion

for Summary Judgment.

On May 22, 2017, R.A.H.’s Motion for Summary Judgment was heard.

Following oral arguments, the trial court granted R.A.H.’s Motion for Summary

Judgment and dismissed Cummins claims with prejudice.

On June 16, 2017, the trial court signed the Judgment granting R.A.H.’s

Motion for Summary Judgment. The trial court did not issue any written reasons

in connection therewith.

2 Cummins timely filed a motion for devolutive appeal. Pursuant to that

motion, Cummins is presently before this court alleging two assignments of error.

ASSIGNMENTS OF ERROR:

1. Under La. R.S. 23:1061(A)(3), “a statutory relationship shall not exist . . . unless there is a written contract . . . which recognizes the principal as a statutory employer.” There is no such contract recognizing R.A.H. as a statutory employer. Accordingly, the trial court erred in granting R.A.H.’s motion for summary judgment based on statutory employer immunity.

2. Under La. Civil Code. art. 1971, “[p]arties are free to contract for any object that is lawful, possible, and determined or determinable.” By contract, R.A.H. agreed that it would not be responsible for workers’ compensation payments to Cummins, and it was not Cummins’ employer. For this additional reason, the trial court erred in granting R.A.H.’s motion for summary judgment based on statutory employer immunity.

ASSIGNMENT OF ERROR NUMBER ONE:

We will address assignment of error number one because the crux of the

matter is whether La.R.S. 23:1061(A)(3), is outcome determinative. Cummins

contends that the lack of a written contract expressly recognizing R.A.H. as

Cummins statutory employer precludes R.A.H. from asserting an affirmative

defense of statutory employer immunity under this statute. We disagree.

In Bankston v. LSU Health Services Center, 09-1334, p. 3 (La.App. 3 Cir.

4/1/09), 7 So.3d 170, this court discussed the standard of review to be employed by

an appellate court when reviewing a motion for summary judgment filed in a

workers’ compensation case:

A motion for summary judgment will be granted “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to material fact and that mover is entitled to judgment as a matter of law.” La.Code Civ.P. art. 966(B). The summary judgment procedure is favored and “is designed to secure the just, speedy, and inexpensive determination” of actions. La.Code Civ.P. art. 966(A)(2). The supreme court in Bonin v. Westport Ins. Corp., 05–0886, p. 4 (La.5/17/06), 930 So.2d 906, 910, stated: 3 This court reviews a grant or denial of a motion for summary judgment de novo. Schroeder v. Board of Supervisors of Louisiana State University, 591 So.2d 342, 345 (La.1991).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Schroeder v. Board of Sup'rs
591 So. 2d 342 (Supreme Court of Louisiana, 1991)
Bankston v. LSU HEALTH SCIENCES CENTER
7 So. 3d 170 (Louisiana Court of Appeal, 2009)
Maddox v. Steel
814 So. 2d 569 (Louisiana Court of Appeal, 2001)
Robinson v. Heard
809 So. 2d 943 (Supreme Court of Louisiana, 2002)
Bonin v. Westport Ins. Corp.
930 So. 2d 906 (Supreme Court of Louisiana, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
Patrick Cummins v. R.A.H. Homes, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patrick-cummins-v-rah-homes-llc-lactapp-2018.