Roderick Sanders on behalf of Himself and A Class Of Similarly Situated Louisiana Residents v. City of Winnfield

CourtLouisiana Court of Appeal
DecidedMay 26, 2021
Docket53,872-CA
StatusPublished

This text of Roderick Sanders on behalf of Himself and A Class Of Similarly Situated Louisiana Residents v. City of Winnfield (Roderick Sanders on behalf of Himself and A Class Of Similarly Situated Louisiana Residents v. City of Winnfield) 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
Roderick Sanders on behalf of Himself and A Class Of Similarly Situated Louisiana Residents v. City of Winnfield, (La. Ct. App. 2021).

Opinion

Judgment rendered May 26, 2021. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 53,872-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

RODERICK SANDERS ON BEHALF OF HIMSELF AND A CLASS OF SIMILARLY SITUATED LOUISIANA RESIDENTS Appellees

versus

CITY OF WINNFIELD Appellants

Appealed from the Eighth Judicial District Court for the Parish of Winn, Louisiana Trial Court No. 45347

Honorable Jacque Derr, Judge

PETTIETTE, ARMAND, DUNKELMAN, WOODLEY, BYRD & CROMWELL, L.L.P. Counsel for Appellants, By: Edwin H. Byrd, III City of Winnfield and Marshall L. Perkins The Charter Oak Fire Insurance Company

LAW OFFICES OF HALES & STRICKLAND Counsel for Appellees By: Myrt T. Hales, Jr. Joshua L. Strickland

Before MOORE, COX, and THOMPSON, JJ. COX, J.

This civil suit arises from the 8th Judicial District Court, Winn Parish,

Louisiana, the Honorable Judge Jacque Derr presiding. The City of

Winnfield (“the City”), the defendant in this matter, appeals from, and seeks

review of a trial court judgment certifying a putative class action filed by

Roderick Sanders (“Mr. Sanders”) individually and on behalf of other

similarly situated persons residing in southwest Winn Parish in April 2017.

For the following reasons, we reverse the judgment of the trial court.

FACTS AND PROCEDURAL HISTORY

On June 5, 2017, Mr. Sanders individually and on behalf of the

residents of southwest Winn Parish instituted this action with the filing of a

class action petition for damages against the City.1 The initial petition named

Mr. Sanders as an individual who purported to represent a class of persons

similarly situated, i.e., those persons within a residential neighborhood in

southwest Winn Parish who sustained damage as a result of flood waters. On

behalf of the putative class, Mr. Sanders alleged that the City of Winnfield

failed to uphold its duties as a Louisiana municipality to properly design,

construct, and maintain the drainage facilities within its jurisdictional limits;

particularly, those facilities in and throughout this area.

According to Mr. Sanders, he and the residents sustained severe

damage from floodwaters after a rainstorm on April 30, 2017,2 as a direct

1 The Charter Oak Fire Insurance Company (“Charter Oak”), the City’s insurer, is also named as a defendant in this suit and is represented by the same counsel. Charter Oak likewise opposed the court’s grant of class certification and joins the City in this appeal. 2 A weather report, included in Mr. Vanderbrook’s assessment of the area, indicated the neighborhood received approximately five to ten inches of rain on the date in question. result of the City’s failure to adequately maintain the drainage facility in this

neighborhood. The petition listed the sustained damages suffered as damage

to property, loss of use, inconvenience, aggravation and distress, and health

hazard(s). Mr. Sanders sought further damages pursuant to the Equal

Protection Clause, 42 U.S.C. §1981, and the La. Constitution, 42 U.S.C.

§1983. He maintained that the City systematically and intentionally

discriminated against him and the residents in this area because its drainage

and land use policies did not protect the property or provide adequate

drainage throughout this area. In particular, the City’s drainage practices

resulted in varying degrees of quality of municipal services and facilities

throughout the residences, prioritizing predominately white neighborhoods to

the detriment of his own neighborhood, which was predominately African

American.

The City removed this matter to the United States District Court for the

Western District of Louisiana. The federal court dismissed, without

prejudice, Mr. Sanders’s federal claims of equal protection violations, finding

that he failed to adequately allege an unconstitutional policy of the City or

that he, as a member of the protected class, was treated differently than other

similarly situated persons outside of the class. The remaining negligence

claims under state tort law were remanded to the district court. The petition

was subsequently amended to exclusively assert a claim of negligence against

the City for failure to adequately design, construct, and maintain its drainage

facilities. The petition stated that the class’s geographic area, or “area of

flooding,” was located “on the west side of Highway 34 and south of West

2 Court Street, east of Pine Ridge Country Club, and north of Country Club

Road.”

Regarding the location, function, and condition of the drainage system

after the City installed culverts and catch basins,3 and prior to the rainstorm

on April 30th, Mr. Sanders attached the opinion of engineer, Kevin C.

Vanderbrook (“Mr. Vanderbrook”). The report provided:

The drainage system in the area is located on the south side of the east/west railroad tracks and on the west side of Highway 34. A drainage canal passed under Highway 34 immediately south of the railroad tracks and this served as the termination point for the watershed which drained the adjacent neighborhood. The system is designed so that the water will drain by means of a two-box culvert under the highway with an additional round culvert. The two openings of the box culvert measure approximately ten (10) feet by ten (10) feet and are located on the east side of a large creek bank which has been partially paved to prevent erosion. On the west side of the creek bank near the highway there is a round culvert which measures approximately five (5) feet in diameter which serves as the termination point for the drainage system of the original Creosote Creek watershed.

The termination of the end round culvert is in extremely bad condition with extensive long-term deterioration to the bottom of the metal culvert. The culvert had originally been asphalt coated but the asphalt has deteriorated to the point where the metal has rusted away, creating an opening along much of the culvert. The culvert has corroded and slumped downward, decreasing the cross-sectional area. Within the culvert system there is widespread deterioration of the drainage pipes though the system with significant corrosion and deterioration to the bottom of the culvert in virtually every section of the pipe, creating both a path for erosion of [soil] and introduction of debris into the pipe. Further, virtually all of the culvert pipe joints were deteriorated and allowed erosion and intrusion of debris into the culvert system.

The culvert pipe extends in a westward direction from Highway 34 approximately one-half (1/2) mile with various branches to secondary culverts and catch basins. There are

3 Mr. Sanders’s petition specified that approximately 20 years before the storm in 2017, the City installed culverts along Creosote Creek, which ran through the area, in an attempt to improve the drainage in the defined area.

3 numerous locations with widespread deterioration of the culvert pipes, widespread intrusion of debris, deterioration of joints and culvert pipes, and significant sloughage and erosion of soil into the culvert system, creating bypasses around the catch basins. In many areas the soil has eroded significantly around the catch basins due to a hole or opening into the culvert pipe and water bypasses the catch basins into the eroded soil area and enters the system through deterioration of either joints or pipes.

Mr.

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Roderick Sanders on behalf of Himself and A Class Of Similarly Situated Louisiana Residents v. City of Winnfield, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roderick-sanders-on-behalf-of-himself-and-a-class-of-similarly-situated-lactapp-2021.