Sarah Eilts v. Twentieth Century Fox Film Corporation, Breakout Kings Production, LLC, and Aaron Nelson

CourtLouisiana Court of Appeal
DecidedMarch 30, 2022
Docket54,252-CA
StatusPublished

This text of Sarah Eilts v. Twentieth Century Fox Film Corporation, Breakout Kings Production, LLC, and Aaron Nelson (Sarah Eilts v. Twentieth Century Fox Film Corporation, Breakout Kings Production, LLC, and Aaron Nelson) 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
Sarah Eilts v. Twentieth Century Fox Film Corporation, Breakout Kings Production, LLC, and Aaron Nelson, (La. Ct. App. 2022).

Opinion

Judgment rendered March 30, 2022. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 54,252-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

SARAH EILTS Plaintiff-Appellant

Versus

TWENTIETH CENTURY FOX Defendants-Appellees FILM CORPORATION, BREAKOUT KINGS PRODUCTION, LLC, AND AARON NELSON

**** Appealed from the Forty-Second Judicial District Court for the Parish of DeSoto, Louisiana Trial Court No. 78,009

Honorable Amy Burford McCartney, Judge

MANNO LAW FIRM, LLC Counsel for Appellant, By: Mark Kenneth Manno Sarah Eilts

McCRANIE, SISTRUNK, ANZELMO, Counsel for Appellees, HARDY, McDANIEL & WELCH, LLC Twentieth Century Fox By: Heather N. Shockley Film Corporation and Breakout Kings Production, LLC

Before THOMPSON, ROBINSON, and O’CALLAGHAN (Pro Tempore), JJ. O’CALLAGHAN (Pro Tempore), J.

In this tort suit, the plaintiff, Sarah Eilts, appeals from a trial court

ruling which granted summary judgment in favor of the defendants,

Breakout Kings Productions, LLC (“Breakout Kings”), and Twentieth

Century Fox Film Corporation (“TCFFC”). Breakout Kings and TCFFC

answered the appeal, contending that the trial court erred in denying their

motion to strike the plaintiff’s untimely opposition memorandum. We

reverse the trial court’s denial of the motion to strike and affirm summary

judgment in favor of the defendants.

FACTS AND PROCEDURAL HISTORY

Eilts worked on the television show “Salem” in several capacities,

including as a “stand-in” and a stunt performer.1 On December 22, 2016,

she filed a petition for damages in which she claimed that she was injured by

Aaron Nelson when he threw her to the ground during the filming of a scene

on January 29, 2016. She alleged that his conduct was an intentional tort

and named him as a defendant, along with Breakout Kings and TCFFC,

which she asserted produced or created “Salem.” As a result of Nelson’s

actions, she claimed to have sustained injuries to her right upper extremity,

right shoulder, and cervical spine. She further alleged that, at the time of the

incident, Nelson was in the course and scope of his employment with

Breakout Kings and/or TCFFC or, alternatively, he was an officer, agent,

and/or assign of them, thus making them vicariously liable for his actions.

1 “Salem” was a Gothic horror television series which filmed in northwest Louisiana from about 2014 to 2016 with a cast that included Shane West, Janet Montgomery, Tamzin Merchant, Xander Berkley, and Lucy Lawless. The incident at issue occurred at a location near the village of Grand Cane in DeSoto Parish. On January 19, 2017, Breakout Kings and TCFFC answered the

petition, generally denying the allegations. 2 They specifically pled tort

immunity and the exclusive remedy provisions of the Louisiana Workers’

Compensation Act as a complete and absolute bar to the recovery sought by

Eilts. In the alternative, they contended that, if Nelson’s actions were

intentional, they were outside the course and scope of his employment.

They also pled such other defenses as comparative fault and assumption of

the risk and requested a jury trial.

On February 1, 2021, Breakout Kings and TCFFC filed a motion for

summary judgment in which they asserted that Breakout Kings was entitled

to tort immunity under the Louisiana Workers’ Compensation Act due to its

status as Eilts’ employer at the time of the incident. As to the intentional act

exception in workers’ compensation, they argued that it required proof that

Breakout Kings or its employee who committed the intentional act (1)

consciously desired the physical result of his act or (2) knew that the result

was substantially certain to follow from his conduct. They also contended

that TCFFC did not employ Eilts or have a role in the production of

“Salem”; its only link was issuing royalty payments to actors like Eilts for

subsequent airings of the show that generated revenue. In support of their

motion, they submitted the following documents: the affidavit of Judd Rea,

a producer for Breakout Kings; the petition for damages; Eilts’ deposition;

and the 1442 corporate representative deposition by Craig Davidson, a

Disney executive.

2 Nelson has never been served and has not made any appearance in the lawsuit. 2 In his affidavit, Rea stated that on January 29, 2016, Eilts was

employed by Breakout Kings as a stunt performer/actor in “Salem” and she

was allegedly injured in the course and scope of her employment while

filming a scene. He stated that on January 20, 2016, she signed an

employment contract with Breakout Kings’ parent company to work as a

“Stunt Refugee Woman” in the first episode of the third season of “Salem.” 3

As a result of her alleged injuries, she made a workers’ compensation claim

with Breakout Kings’ workers’ compensation insurer and received medical

benefits and indemnity payments. According to Rea’s affidavit, the insurer

was still paying indemnity payments to Eilts. He stated that Breakout Kings

did not intend or desire for Eilts to be injured while working on “Salem.”

Rea further stated that there was no corporate relationship between TCFFC

and Breakout Kings at the time of the incident, except 21st Century Fox

America, Inc., ultimately owned both entities, and that TCFFC had no role

in the production of “Salem.” While the initial workers’ compensation

documentation erroneously identified Twentieth Century Fox TV as Eilts’

employer, he stated that her claim had since been redesignated internally.

In her deposition, Eilts indicated that she worked on “Salem” for two

and a half to three years. She was “uncertain” as to whether she had signed

a contract to work on “Salem.” She had worked in several positions,

including a speaking actor, a body double, a stand-in, and a stunt performer.

She admitted making a workers’ compensation claim for the incident in

question. She was “uncertain” as to whether they had paid her medical

expenses but conceded that she was receiving about $500 in income per

3 However, a copy of this contract shown to Davidson during his deposition was dated “1/29/16.” 3 week. As to the actual incident, she stated that she was initially standing in

for an actor and then she was paid as a stunt performer. In what was

apparently a rape scene, she was thrown to the ground violently enough to

separate her shoulder. She asserted that she was upgraded to a stunt position

after she got “beat up.” She finally admitted that she was told, in relation to

the scene being filmed, that there was going to be a raid on the town and she

would be “crawling away.” She further admitted that she was thrown down

more than once while filming the scene. She was “not certain” when she got

“badly injured.” She stated that she went to an urgent care facility the next

day for treatment.

When questioned about evidence pertaining to the defendants’

intentions, Eilts testified as follows:

Q: Do you believe that Aaron Nelson intended to hurt you? A: I can’t say. Q: You don’t think he did? A: I--I’m un--I--I don’t know. Q: Okay. Do you have any evidence that he intended to hurt you? A: Not-- not that I can think of, other than the fact that I’m hurt. ... Q: Do you have any evidence that Twentieth Century Fox intended for you to be injured? A: Not to my knowledge. Q.

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

Related

Caudle v. Betts
512 So. 2d 389 (Supreme Court of Louisiana, 1987)
Carrier v. Grey Wolf Drilling Co.
776 So. 2d 439 (Supreme Court of Louisiana, 2001)
Berry v. Valley Gin, Inc.
16 So. 3d 494 (Louisiana Court of Appeal, 2009)
Simoneaux v. Excel Group, LLC
936 So. 2d 1246 (Supreme Court of Louisiana, 2006)
Cole v. Department of Public Safety
825 So. 2d 1134 (Supreme Court of Louisiana, 2002)
Bazley v. Tortorich
397 So. 2d 475 (Supreme Court of Louisiana, 1981)
Reeves v. Structural Preservation Systems
731 So. 2d 208 (Supreme Court of Louisiana, 1999)
Guarino v. Kaiser Aluminum & Chemical
712 So. 2d 989 (Louisiana Court of Appeal, 1998)
Young v. Doe
67 So. 3d 632 (Louisiana Court of Appeal, 2011)
Gardner v. Craft
137 So. 3d 69 (Louisiana Court of Appeal, 2014)
Peironnet v. Matador Resources Co.
144 So. 3d 791 (Supreme Court of Louisiana, 2013)
Crockett v. Therral Story Well Service, Inc.
57 So. 3d 355 (Louisiana Court of Appeal, 2011)
Chabert v. Mothe Life Insurance Co.
890 So. 2d 621 (Louisiana Court of Appeal, 2004)

Cite This Page — Counsel Stack

Bluebook (online)
Sarah Eilts v. Twentieth Century Fox Film Corporation, Breakout Kings Production, LLC, and Aaron Nelson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sarah-eilts-v-twentieth-century-fox-film-corporation-breakout-kings-lactapp-2022.