Randall Vincent and Karen Vincent v. City of Iowa

CourtLouisiana Court of Appeal
DecidedApril 11, 2018
DocketCA-0017-0951
StatusUnknown

This text of Randall Vincent and Karen Vincent v. City of Iowa (Randall Vincent and Karen Vincent v. City of Iowa) 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
Randall Vincent and Karen Vincent v. City of Iowa, (La. Ct. App. 2018).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

17-951

RANDALL VINCENT AND KAREN VINCENT

VERSUS

CITY OF IOWA

**********

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 2015-439 HONORABLE RONALD F. WARE, DISTRICT JUDGE

MARC T. AMY JUDGE

Court composed of Marc T. Amy, Shannon J. Gremillion, and Candyce G. Perret, Judges.

AFFIRMED.

Jerry J. Falgoust Falgoust and Caviness, L.L.P. 505 S. Court Street Opelousas, LA 70571-1450 (337) 942-5812 COUNSEL FOR DEFENDANT/APPELLANT: City of Iowa

Gregory P. Marceaux Marceaux Law Firm, LLC 2901 Hodges Street Lake Charles, LA 70601 (337) 310-2233 COUNSEL FOR PLAINTIFFS/APPELLEES: Randall Vincent Karen Vincent AMY, Judge.

The plaintiffs filed suit after a City sewerage line discharged into their home

in 2014, causing damage to their home as well as their personal property.

Although the City provided for certain repairs to the home, as well as relocation

expenses while their home was being repaired, the City denied their remaining

claim. It instead challenged the extent of the plaintiffs’ loss and asserted that the

plaintiffs failed to properly mitigate their damages. The trial court found in the

plaintiffs’ favor as to a first incidence of sewage discharge, awarding damages for

certain contents of the home, mental anguish, and loss of use. The trial court

denied damages associated with a second sewage discharge event. The City

appeals. The plaintiffs answer the appeal, seeking additional damages. For the

following reasons, we affirm.

Factual and Procedural Background

The plaintiffs, Karen and Randall Vincent, allege that on February 2, 2014,

they discovered sewage overflowing from a toilet into their Iowa home while

preparing for a Super Bowl Sunday gathering. The discharge was subsequently

found attributable to blockage in the City of Iowa’s sewerage line.

Mrs. Vincent explained that, while preparing for her party, she noticed that

her feet had become wet and that she subsequently discovered the sewage waste

coming from a toilet in what appeared to her to be a “volcano[.]” The record

indicates that the sewage flowed into multiple rooms of the home and reached

accumulations of up to two inches. Mr. Vincent was able to stop the overflow by

releasing a “washout cap” outside of the home. He explained, however, that once

the cap was opened, “[e]verything started gushing out there on the ground. The

toilet paper, fecal matter … you can just about imagine.” With the overflow stopped, the plaintiffs, along with family members,

immediately began to remove the accumulation of what was identified as raw

sewage from the interior of the home that evening, doing so until approximately

midnight. The City was contacted the following day, with its Public Works

Director visiting the home. Although testimony indicated that an obstruction in the

line was identified and remedied, the plaintiffs alleged that a second overflow

occurred on February 5, 2014. Mrs. Vincent explained that she discovered the

second overflow, which purportedly occurred in the master bathroom.

A few nights later, the plaintiffs, along with their daughter and three

grandchildren, 1 relocated to two adjoining rooms at a nearby hotel due to

conditions in the home and so that repairs could be made. With regard to the latter,

a contractor began working in the home, replacing flooring, replacing sheetrock,

and painting the interior. During that period of construction, the plaintiffs stored

much of the home’s contents in a storage “pod” placed on their driveway for that

purpose.

The plaintiffs and their family returned to their home from the hotel after

approximately two months. By that time, the City had compensated the plaintiffs

for their hotel stay and for related living expenses. Additionally, the City approved

the payment of approximately $29,000.00 in repairs to the home. However, the

City rejected the plaintiffs’ claim for damages associated with the second

discharge, that allegedly occurring in the master bathroom on February 5, 2014.

Mr. and Mrs. Vincent filed this matter in January 2015, alleging that the

City’s negligence in the maintenance and inspection of the sewerage system was

1 The record indicates that the plaintiffs’ daughter and her three children also lived in the home.

2 the sole cause of the occurrence. The plaintiffs sought an award for property

damage, depreciation of property, mental anguish and emotional distress, loss of

earnings, rental expenses, and other unnamed damages. Following a two-day

bench trial, the trial court found in favor of the plaintiffs, concluding that “there’s

no doubt that the City of Iowa is responsible for the February 2nd, ꞌ14 overflow

and the … backflow into [the] house.” However, the trial court denied certain

claimed damages, but awarded damages as follows: $45,699.00 for contents

damages; $75,000.00 for mental anguish damages ($35,000.00 to Mr. Vincent and

$40,000.00 to Mrs. Vincent); and $60,000.00 for loss of use. The trial court

imposed the latter loss of use award with a $15,061.00 credit in favor of the City

for “loss of use damages previously paid[.]” The trial court denied an award

associated with the alleged February 5, 2014 overflow.

The City appeals, asserting that the trial court: 1) abused its discretion in

awarding a total of $75,000.00 for mental anguish; 2) abused its discretion in

awarding $60,000.00 for loss of use of the residence (with a $15,061.00 credit for

hotel expenses previously paid); and that it 3) was manifestly erroneous in its

award of $45,699.00 for household property based upon what it considers were

unreliable value estimates. The plaintiffs answer the appeal, seeking an additional

$8,411.51 for replacement items purchased and $31,256.00 for further damages

associated with the repair of the home.

Discussion

Mental Anguish Damages

In its first assignment of error, the City questions whether the plaintiffs

“experienced trauma as a result of the property damage and, if so, did the Trial

Court’s finding that Randall and Karen Vincent were entitled to awards for mental

3 anguish of $35,000[.00] and $40,000[.00] respectively, represent an abuse of

discretion[.]”

As a starting point, we note that an award of damages for mental anguish

arising from property damage is limited to situations in which property is

damaged: 1) by a tortfeasor’s “intentional or illegal act”; 2) by an act “for which

the tortfeasor will be strictly or absolutely liable”; 3) by an act “constituting a

continuing nuisance”; or 4) “when the owner is either present or nearby and

suffered a psychic trauma as a direct result.” Zaveri v. Husers, 16-866, 16-867, p.

21 (La.App. 3 Cir. 6/21/17), 224 So.3d 389, 404-05 (quoting Holzenthal v.

Sewerage & Water Bd. of New Orleans, 06-0796, p. 39 (La.App. 4 Cir. 1/10/07),

950 So.2d 55, 79, writ denied, 07-0294 (La. 3/30/07), 953 So.2d 71), writ denied,

17-1286 (La. 11/6/17), 229 So.3d 475. As related above, it is uncontested that the

plaintiffs in this case were in their home, witnessing and personally addressing the

offending overflow of sewage into the home.2

In Zaveri, 224 So.3d 389, a panel of this court explained that, although

mental anguish damages may be appropriate in cases involving property damage,

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Randall Vincent and Karen Vincent v. City of Iowa, Counsel Stack Legal Research, https://law.counselstack.com/opinion/randall-vincent-and-karen-vincent-v-city-of-iowa-lactapp-2018.