Reba Campbell, Et Ux. v. Evangeline Parish Police Jury

CourtLouisiana Court of Appeal
DecidedMay 6, 2015
DocketCA-0014-1301
StatusUnknown

This text of Reba Campbell, Et Ux. v. Evangeline Parish Police Jury (Reba Campbell, Et Ux. v. Evangeline Parish Police Jury) 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
Reba Campbell, Et Ux. v. Evangeline Parish Police Jury, (La. Ct. App. 2015).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

14-1301

REBA CAMPBELL AND BRENT CAMPBELL

VERSUS

EVANGELINE PARISH POLICE JURY, ET AL.

**********

APPEAL FROM THE THIRTEENTH JUDICIAL DISTRICT COURT PARISH OF EVANGELINE, NO. 70506-A HONORABLE J. LARRY VIDRINE, DISTRICT JUDGE

MARC T. AMY JUDGE

Court composed of Marc T. Amy, James T. Genovese, and John E. Conery, Judges.

AFFIRMED IN PART; REVERSED IN PART; REMANDED FOR FURTHER PROCEEDINGS.

Jonathan C. Vidrine Post Office Drawer 1019 Ville Platte, LA 70586 (337) 363-2772 COUNSEL FOR PLAINTIFFS/APPELLEES: Reba Campbell Brent Campbell Michael W. Landry Assistant Attorney General One Lakeshore Dr., Suite 1200 Lake Charles, LA 70629 (337) 491-2880 COUNSEL FOR DEFENDANT/APPELLANT: State of Louisiana, Department of Health and Hospitals

Marcus L. Fontenot Assistant District Attorney Post Office Drawer 780 Ville Platte, LA 70586 (337) 363-3438 COUNSEL FOR DEFENDANT/APPELLEE: Evangeline Parish Police Jury AMY, Judge.

The plaintiff contends that she slipped on a sidewalk outside the Evangeline

Parish Medicaid Office and was injured as a result. The plaintiff and her husband

filed suit against the owner of the building, the Evangeline Parish Police Jury, and

the lessee of the building, the State of Louisiana, Department of Health and

Hospitals. The lease between the Police Jury and the State contained an indemnity

provision, and the plaintiffs filed a petition for declaratory judgment seeking a

determination of whether the Police Jury would be responsible for damages

pursuant to the indemnity provision or whether the State was responsible for

damages because its employees assumed responsibility for the sidewalk. The trial

court found that the State failed to notify the Police Jury about the condition of the

sidewalk and that the State was liable for the plaintiff’s injuries. The trial court

also dismissed the Police Jury from the litigation. The State appeals. We affirm in

part, reverse in part, and remand for further proceedings.

Factual and Procedural Background

According to the petition, Reba Campbell was walking on the sidewalk

adjacent to the Evangeline Parish Medicaid Office when she slipped on a black or

greenish area of the sidewalk and fell. Mrs. Campbell alleges that she was injured

as a result. Both Mrs. Campbell and her husband, Brent Campbell, filed suit

against the Evangeline Parish Police Jury, as the owner of the Medicaid Office

building, and the State of Louisiana, Department of Health and Hospitals, as the

lessee of the building. In its answer, the State asserted a cross-claim against the

Police Jury on the basis that the lease between the State and the Police Jury

provided that the Police Jury indemnify the State for any damages assessed due to the Police Jury’s negligence and that the lease required the Police Jury to maintain

the sidewalks.

Thereafter, the plaintiffs filed a petition for declaratory judgment, seeking a

determination of the rights of the parties under the lease, specifically whether the

Police Jury was responsible under the provisions of the lease or whether the State

had assumed responsibility for the sidewalks due to the actions of its employees.

There was a hearing on that issue, at which the State’s request for involuntary

dismissal was denied. Subsequently, the trial court found that, although the Police

Jury was responsible for maintaining the building, the State had not notified the

Police Jury about this particular problem. Further, the trial court found that the

State “did not take sufficient steps to insure the safety of its patrons who

frequented or used the Medicaid offices[.]” Thus, the trial court determined that

the State was responsible to the plaintiffs for Mrs. Campbell’s injuries. The trial

court also granted the Police Jury’s oral motion for judgment as a matter of law

and dismissed the Police Jury from the suit.

The State appeals, assigning as error:

1. The trial court was manifestly erroneous in determining that the State as lessee is responsible for the injuries resulting to Campbell.

2. The trial court was manifestly erroneous in denying the state’s motion for judgment as a matter of law at the close of plaintiff’s case.

3. The trial court was manifestly erroneous in determining that the police jury is not responsible for injuries caused by any defects in its premises which caused harm to Campbell.

4. The trial court committed legal error in dismissing a party after a hearing noticed for the limited purpose of hearing a petition for declaratory judgment.

5. The trial court committed legal error in dismissing the state’s cross claim for indemnity as there was no evidence to support any

2 conclusion other than the agreement between the parties to the lease was that the police jury defendant indemnify the state against any claim for damages resulting from the police jury’s negligence in failing to maintain the premises.

Discussion

Declaratory Judgment

The plaintiffs requested a declaratory judgment addressing whether the State

or the Police Jury was liable to the plaintiffs for Mrs. Campbell’s injuries. 1

Pursuant to La.Code Civ.P. art. 1871, “[c]ourts of record within their respective

jurisdictions may declare rights, status, and other legal relations whether or not

further relief is or could be claimed.” Further, La.Code Civ.P. art. 1872 states that:

[a] person interested under a deed, will, written contract or other writing constituting a contract, or whose rights, status, or other legal relations are affected by a statute, municipal ordinance, contract or franchise, may have determined any question of construction or validity arising under the instrument, statute, ordinance, contract, or franchise and obtain a declaration of rights, status, or other legal relations thereunder.

Thus, the function of a declaratory judgment is to establish the rights of the

parties or to express the court’s opinion on a question of law without ordering any

relief. MAPP Constr., LLC v. Amerisure Mut. Ins. Co., 13-1074 (La.App. 1 Cir.

3/24/14), 143 So.3d 520. “Trial courts are vested with wide discretion in deciding

whether or not to grant or refuse declaratory relief.” In re Interment of LoCicero,

05-1051, p. 4 (La.App. 4 Cir. 5/31/06), 933 So.2d 883, 886. However, where the

judgment would terminate an uncertainty or controversy which gave rise to the

proceeding, the trial court must render a declaratory judgment. Id. See also

La.Code Civ.P. art. 1876. Accordingly, the appellate court is limited to a

1 We observe that, although styled as a petition for declaratory judgment seeking an interpretation of the lease provisions, the proceedings in this matter are more akin to a bifurcated bench trial on the issue of liability. See La.Code Civ.P. art. 1915.

3 determination of whether the trial court abused its discretion in its grant of or

refusal to render a declaratory judgment. Id.

Although the trial court’s determination about whether to issue a declaratory

judgment is subject to the abuse of discretion standard, the judgment itself is still

subject to the appropriate standard of review—questions of law are reviewed de

novo and questions of fact are subject to the manifest error/clearly wrong standard

of review. See Ranger Ins. Co. v. Shop Rite, Inc., 05-452 (La.App. 5 Cir. 1/17/06),

921 So.2d 1040.

Responsibility of the Police Jury for Maintenance

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