Scottsdale Insurance Co v. Mott

CourtDistrict Court, W.D. Louisiana
DecidedMay 20, 2025
Docket2:25-cv-00256
StatusUnknown

This text of Scottsdale Insurance Co v. Mott (Scottsdale Insurance Co v. Mott) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Scottsdale Insurance Co v. Mott, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAKE CHARLES DIVISION SCOTTSDALE INSURANCE CO CASE NO. 2:25-CV-00256 VERSUS JUDGE JAMES D. CAIN, JR. ROBERT S MOTT ET AL MAGISTRATE JUDGE LEBLANC MEMORANDUM RULING Before the Court is a “Motion to Dismiss” (Doc. 12) filed by Defendants Robert S.

Mott and Kristi Trahan. Defendants move to dismiss this Declaratory Judgment Action because there is currently a state court action pending in the 14th Judicial District Court. BACKGROUND Plaintiff, Scottsdale Insurance Company (“Scottsdale”) filed this Declaratory Action against Defendants, Robert S. Mott, Kristi Trahan and Garrison Industrial Services,

Inc. (“Garrison 1”) for the purpose of determining the parties’ respective rights and obligations under a policy of insurance issued by Scottsdale to Garrison 1 during the relevant time period. Specifically, Scottsdale seeks a judgment declaring that it has no duty to defend or indemnify Garrison 1 under either the primary policy or the excess policy with respect to a lawsuit filed by Robert Mott and Kristi Trahan in the 14th Judicial District Court.1

1 Robert S. Mott and Kristi Trahan v. Garrison Industrial Services, Inc. and Alfred Palma LLC, Civ. Action No. 2024-000577 (the “underlying lawsuit”)The suit was originally filed against Garrison 1, but was later amended to include Garrison 2. Scottsdale filed this Declaratory action and Plaintiffs have sought to amend the state court lawsuit and add Scottsdale as a defendant. Plaintiff’s exhibit 2. The underlying lawsuit involves the death of Alex Mott on November 16, 2023, as he was installing can lights in the ceiling of a building being constructed on behalf of Waste Management in Lake Charles, Louisiana.2 Robert S. Mott and Kristi Trahan are the parents

of Mr. Mott, who was twenty years old when he was killed while working as an electrical apprentice with Garrison Industries, Inc. Garrison 1 was contracted by Alfred Palma, LLC (“Palma”) to perform electrical services on the project and Mr. Mott, an employee of Garrison Industries, Inc.,(“Garrison 2”)3 was performing the work pursuant to the contract between Garrison 1 and Palma.4

Scottsdale denied coverage for Garrison 1 based upon the worker’s compensation exclusion in the policy,5 but agreed to defend Garrison 1 in the underlying lawsuit. Scottsdale alleges that Garrison 2 operates as a staffing company separate from Garrison 1, but with a common ownership through Mr. Brian Davis.6 Scottsdale also alleges that Garrison 1 would “borrow” employees from Garrison 2 to work on jobs.7 Garrison 1 and

Garrison 2, both carry their own workers’ compensation insurance coverage.

2 Complaint, ¶ 8, Doc. 1. 3 In the state court lawsuit, Plaintiffs originally pled that Mr. Mott was employed by Garrison Industrial Services, Inc, but later filed an Amended Petition alleging that Mr. Mott was employed by Garrison Industries, Inc., not Garrison Industrial Services, Inc. In the state court suit, the parties dispute whether Mr. Mott was Garrison 1’s employee (implicating the exclusive remedy of workers’ compensation) and whether Garrison 1 or its agents committed an intentional tort. Doc. 1-3. 4 Id. ¶ 9-11. 5 Plaintiff’s exhibit 5, Doc. 1. 6 Complaint, ¶ 14, Doc. 1. 7 Id. ¶ 15. Garrison 2 is not included as a Named Insured in the Named Insured Schedule Endorsement, nor is it identified as a Named Insured in the Declarations of the Garrison 1 policy.8 Garrison 2’s compensation carrier paid out death benefits for Mr. Mott’s death.

In the underlying lawsuit in state court, Garrison 2 has taken the position that Plaintiff’s tort damages against their son’s employer (Garrison 2) are precluded because of the Louisiana Workers’ Compensation Act’s (“LWCA”) exclusive remedy; Garrison 1 has taken the position that Mr. Mott was a “borrowed servant” and therefore any claims by Plaintiffs against Garrison 1 are likewise precluded under the LWCA. Additionally,

Scottsdale posits that Plaintiffs’ claims do not meet the requirements for coverage under the Excess Policy based on the terms and exclusions outlined in both the Excess Policy and the Primary Policy. Plaintiffs in the underlying lawsuit take the position that Mr. Mott did not qualify as an “employee”, and as a matter of law should be considered a subcontractor to

Scottsdale’s Named Insured. LAW AND ANALYSIS In its Motion, Defendants are asking the Court to abstain and dismiss this lawsuit and allow the state court to decide the issues raised by Scottsdale because the state court suit and this lawsuit are parallel proceedings in which all coverage issues can be

adjudicated in the state court lawsuit.

8 Plaintiff’s exhibit 1. The Declaratory Judgment Act, 28 U.S.C. § 2201, confers no jurisdiction but is a procedural device designed to provide a new remedy to the federal court arsenal. Aetna

Life Ins. Co. of Hartford, Conn. V. Haworth, 300 U.S. 227, 239-40, 57 S.Ct. 461, 463-464 (1937). The district court, however, is not required to provide declaratory judgment relief, and it is a matter for the district court’s sound discretion whether to decide a declaratory judgment action. Brillhart v. Excess Ins. Co. of America, 316 U.S. 491, 62 S.Ct. 1173 (1942); Hollis v. Itawamba county Loans, 657 F.2d 746, 750 (5th Cir. 1981). The “district courts may not decline on the basis of whim or personal

disinclination.” Hollis, 657 F.2d at 750, but may take into account a wide variety of factors. Mission Ins. Co. v. Puritan Fashions Corp., 706 F.2d 599, 601 (5th Cir. 1983). In determining whether to abstain, the Court must review the case pursuant to the Trejo factors, which non-exclusively include: 1) whether there is a pending state action in which all of the matters in controversy may be fully litigated, 2) whether the plaintiff filed suit in anticipation of a lawsuit filed by the defendant, 3) whether the plaintiff engaged in forum shopping in bringing the suit, 4) whether possible inequities in allowing the declaratory plaintiff to gain precedence in time or to change forums exist, 5) whether the federal court is a convenient forum for the parties and witnesses, ... 6) whether retaining the lawsuit in federal court would serve the purposes of judicial economy,” and ... [7) ] whether the federal court is being called on to construe a state judicial decree involving the same parties and entered by the court before whom the parallel state suit between the same parties is pending.” Ironshore Specialty Ins. Co. v. Tractor Supply Co., 624 F. App'x 159, 164 (5th Cir. 2015), citing St. Paul Insurance Co. v. Trejo, 39 F.3d 585 (5th Cir. 1994).

Whether there is a pending state action in which all of the matters in controversy may be fully litigated

“[I]f the federal declaratory judgment action raises only issues of state law and a state case involving the same state law issues is pending, generally the state court should decide the case and the federal court should exercise its discretion to dismiss the federal suit.” Sherwin-Williams Co. v. Holmes County, 343 F.3d (5th Cir. Aug. 13, 2003). Here, Defendants assert that the main issue in both the state and federal proceedings is the employment status of Mr. Mott with regard to Garrison 1, and whether are not Garrison 1 committed an intentional tort.

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Related

St. Paul Insurance v. Trejo
39 F.3d 585 (Fifth Circuit, 1994)
Aetna Life Insurance v. Haworth
300 U.S. 227 (Supreme Court, 1937)
Brillhart v. Excess Insurance Co. of America
316 U.S. 491 (Supreme Court, 1942)
James Hollis v. Itawamba County Loans
657 F.2d 746 (Fifth Circuit, 1981)
Ironshore Specialty Insurance v. Tractor Supply Co.
624 F. App'x 159 (Fifth Circuit, 2015)

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Scottsdale Insurance Co v. Mott, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scottsdale-insurance-co-v-mott-lawd-2025.