Sabrina Scott v. Jennifer Adams and Kenneth Adams III

CourtLouisiana Court of Appeal
DecidedFebruary 17, 2022
Docket2021CA0589
StatusUnknown

This text of Sabrina Scott v. Jennifer Adams and Kenneth Adams III (Sabrina Scott v. Jennifer Adams and Kenneth Adams III) 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
Sabrina Scott v. Jennifer Adams and Kenneth Adams III, (La. Ct. App. 2022).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

NO. 2021 CA 0589

SABRINA SCOTT

VERSUS

JENNIFER ADAMS AND KENNETH ADAMS, III

Judgment Rendered: FEB 17 2022

On Appeal from the 22nd Judicial District Court In and for the Parish of St. Tammany State of Louisiana Trial Court No. 2017- 14333

Honorable August J. Hand, Judge Presiding

Galen M. Hair Attorneys for Plaintiff A - ppellant Trent Moss Sabrina Scott Metairie, LA and

Kristin M. Lausten New Orleans, LA

Shannon Howard -Eldridge Attorneys for Defendants -Appellees, Lauren A. Williams Jennifer Adams and Kenneth Adams, III Mandeville, LA and

John M. Robin Catherine M. Robin Covington, LA

BEFORE: WHIPPLE, C. J., PENZATO, AND RESTER, JJ. HESTER, J.

This appeal is from the trial court' s grant of summary judgment in favor of

the lessor/owners of a leased residence dismissing the claims of the lessee for bodily

injury and property damages allegedly caused by exposure to mold in the residence.

For the following reasons, we affirm.

FACTS AND PROCEDURAL HISTORY

In 2007, Kenneth Adams, III as the residential contactor for his construction

company, built a home at 905 Agnes Street in Mandeville, Louisiana. After the

home was complete, he and his wife, Mrs. Jennifer Adams lived there with their

family until 2015. After they moved out, on November 27, 2015, Mr. Adams entered

into a " Standard Residential Lease Agreement" with Ms. Sabrina Scott for the lease

of the Agnes Street home from December 1, 2015 to December 1, 2016 and

continuing month to month thereafter.

Around July 8, 2017, approximately seventeen months after Ms. Scott moved

into the home, she discovered that the electrical outlets on the backsplash and

cooktop in her kitchen were not working. Ms. Scott looked in the cabinet under the

cooktop and noticed what appeared to be mold growing inside the cabinet. In the

afternoon on Saturday, July 8, 2017, she texted Mr. Adams to let him know that the

electricity to the cooktop went out and when she looked in the cabinet under the

cooktop she discovered " a major mold problem." In the text, she also told Mr.

Adams that she was highly allergic to mold. Mr. Adams responded that he would

be there Monday. On Monday afternoon, Mr. Adams came to the home and cleaned

the surface of the cabinet. He returned to the home the next day to work on the

cooktop and continue cleaning.

On July 17, 2017, Ms. Scott again texted Mr. Adams, " I don' t think this mold

is all gone. It needs to be fully remediated... I can only be there briefly before feeling

sick." Mr. Adams returned to the home to attempt to test for mold. At some point,

2 communication between Ms. Scott and Mr. Adams deteriorated, and the Adamses

were unable to access the home. On July 27, 2017, Ms. Scott hired Mr. Brent

Driskill, a licensed mold remediation contractor, to perform an environmental

assessment of the Agnes Street home. While Mr. Driskill was inspecting the home,

Mrs. Adams came to the home. The next day, Mr. Adams initiated an eviction

proceeding against Ms. Scott, and on August 2, 2017, an order was signed mandating

Ms. Scott to vacate the premises.

Ms. Scott filed suit on September 19, 2017, against Mr. and Mrs. Adams for

wrongful eviction and for damages caused by exposure to mold in the Agnes Street

home. In her petition, Ms. Scott stated the action or inaction of the Adamses caused

the mold, and the mold caused her to suffer substantial negative health effects and

damages to her personal property. The Adamses answered Ms. Scott' s suit and filed

a reconventional demand alleging that Ms. Scott violated the terms of the lease and

caused damage to their property. On July 23, 2018, the Adamses filed a motion for

summary judgment, which was denied except for Ms. Scott' s claims related to the

wrongful eviction.

Thereafter, the parties engaged in extensive discovery involving multiple

experts and depositions. On May 1, 2020, the Adamses filed a second motion for

summary judgment on two grounds. First, the Adamses contended that Ms. Scott' s

suit should be dismissed because the terms of the lease agreement contain waivers

of liability in favor of them as the lessors whereby they are not responsible for the

personal injury and property damages Ms. Scott pursued in her petition. Second, the

Adamses contended that Ms. Scott cannot show general or specific causation

required for toxic mold cases because she does not have medical evidence to show

mold exposure or that mold exposure caused her to suffer any injury or illness.

3 Ms. Scott also filed a motion for summary judgment regarding the Adamses'

reconventional demand for property damages and a partial motion for summary

judgment regarding damages to her property and medical damages.

Ms. Scott responded to the Adamses' motion for summary judgment,

contending that the waiver in the lease was ineffective because under La. R. S. 9: 3221

the Adamses knew or should have known of the defect that caused the mold and

further that the Adamses failed to remedy the mold within a reasonable time after

receiving notice of the defect. Further, Ms. Scott contends that she provided ample

medical evidence to prove that she was exposed to mold and the exposure caused

her to suffer health problems.

The Adamses' motion for summary judgment and Ms. Scott' s motion for

summary judgment and partial motion for summary judgment came before the court

for a hearing on July 8, 2020. After argument, the trial court in oral reasons

determined that the waiver in the lease agreement applied whereby the Adamses are

exempt from liability for Ms. Scott' s injury caused by mold in the home. Therefore,

the trial court granted summary judgment in favor of the Adamses and pointed out

that most of the remaining issues were moot. The trial court also granted summary

judgment in favor of Ms. Scott regarding the Adamses' reconventional demand for

property damages.

On July 30, 2020, the trial court signed a judgment in conformance with its

oral reasons granting the Adamses' motion for summary judgment and dismissing

Ms. Scott' s suit against them with prejudice; denying Ms. Scott' s motion for

summary judgment relating to her claims for contents damages and injuries; and

granting Ms. Scott' s motion for summary judgment related to the Adamses'

reconventional demand for property damages. It is from this judgment that Ms. Scott

appeals, assigning error only to the motion for summary judgment granted in favor

of the Adamses. Ms. Scott contends that the trial court erred in upholding the waiver

11 clause in the lease agreement where the Adamses, as the builders of the home, knew

or should have known of defects in the home; where the Adamses failed to remedy

the defects causing the formation of mold; and where the Adamses' negligence led

to substantial physical injuries to Ms. Scott and damage to her personal property.

LAW AND ANALYSIS

A motion for summary judgment is a procedural device used to avoid a full-

scale trial when there is no genuine issue of material fact. Jones v. Anderson, 2016-

1361 ( La. App. 1st Cir. 6/ 29/ 17), 224 So. 3d 413, 417. After an opportunity for

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