Shandi Thibodeaux v. McNeese State University

CourtLouisiana Court of Appeal
DecidedJanuary 25, 2023
DocketCA-0022-0450
StatusUnknown

This text of Shandi Thibodeaux v. McNeese State University (Shandi Thibodeaux v. McNeese State University) 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
Shandi Thibodeaux v. McNeese State University, (La. Ct. App. 2023).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

22-450

SHANDI THIBODEAUX

VERSUS

MCNEESE STATE UNIVERSITY

**********

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 2020-3899 HONORABLE DAVID A. RITCHIE, DISTRICT JUDGE

ELIZABETH A. PICKETT CHIEF JUDGE

Court composed of Elizabeth A. Pickett, Jonathan W. Perry, and Ledricka J. Thierry, Judges.

REVERSED AND REMANDED WITH INSTRUCTIONS.

Jeff Landry Attorney General Jennie P. Pellegrin Neuner Pate 1001 West Pinhook Road Lafayette, LA 70503 (337) 237-7000 COUNSEL FOR DEFENDANT-APPELLEE: McNeese State University

E. Jacob Colonna Colonna Law Firm, LLC 900 Ryan Street, Suite 402 Lake Charles, LA 70601 (337) 656-3212 COUNSEL FOR PLAINTIFF-APPELLANT: Shandi Thibodeaux PICKETT, Judge.

The plaintiff appeals the trial court’s judgment granting the attorney

general’s exception of improper citation and service and dismissing all her claims

for wrongful termination against the university where she was formerly employed.

For the following reasons, we reverse the trial court’s judgment.

FACTS

On November 12, 2020, Shandi Thibodeaux filed suit against McNeese

State University, alleging she was wrongfully terminated from her position as

librarian. Ms. Thibodeaux named the Board of Supervisors of the University of

Louisiana System through McNeese State University as defendant and directed

that citation and service be made on McNeese at the address stated in the petition.

Ms. Thibodeaux entered a preliminary default against McNeese on June 29, 2021.

On August 24, 2021, the Louisiana Attorney General (AG) enrolled as counsel and

filed declinatory exceptions of insufficient service and/or service of process, lack

of personal jurisdiction, and dilatory exceptions of lack of subject-matter

jurisdictin, prematurity, and vagueness/ambiguity.

On January 26, 2022, the trial court conducted a hearing on the AG’s

exceptions and granted his declinatory exception of insufficient citation and/or

service of process and dismissed Ms. Thibodeaux’s claims. The trial court

determined the remaining exceptions were rendered moot by that determination.

Ms. Thibodeaux appeals the trial court’s judgment.

ASSIGNMENT OF ERROR

Ms. Thibodeaux assigns error with the trial court’s granting the exception of

insufficient citation and/or service of process. She asserts this error presents three

issues for our review: (1) Whether the trial court erred in holding that La. Rev. Stat. Ann. § 13:5107 requires that service be requested within 90 days on the Louisiana Attorney General, or can service be requested within the requisite time period on “any other officer or person” or “officer through which or through whom suit is to be filed”, specifically that service may be requested on the department, board, commission, or agency head within the 90-day time limit of the statute?

(2) Whether the trial court erred in holding that service on an executive officer “or any employee of suitable age and discretion”, pursuant to Code of Civil Procedure article 1265, is suitable to satisfy the service requirements of La. Rev. Stat. Ann. § 13:5107(A)(1) and/or La. Rev. Stat. Ann. § 13:5107 (D)(1)[?]

(3) Does La. Rev. Stat. Ann. § 13:5107(D)(2) permit dismissal of a suit brought against the state, a political subdivision, and/or state agency if the petitioner fails to request service on the Louisiana Attorney General pursuant to La. Rev. Stat. Ann. § 13:5107(A)(2), or does La. Rev. Stat. Ann. § 13:5107(D)(2) only prohibit dismissal if the requirements of La. Rev. Stat. Ann. § 13:5107(D)(1) are not met?

DISCUSSION

When “the facts are not disputed, the ruling on exceptions of insufficiency of

citation and service of process is subject to a de novo standard of review.” Brown

v. Chesson, 20-730, p. 2 (La. 3/24/21), 315 So.3d 834, 836. Furthermore, the

exceptions at issue require an interpretation of La.R.S. 13:5107 and La.R.S.

39:1538 in light of the facts at issue which present “a question of law subject to de

novo review.” Id.

In his exception of improper citation and service, the AG asserts Ms.

Thibodeaux’s claims should be dismissed because she failed to comply with the

service requirements of La.R.S. 13:5107 and La.R.S. 39:1538 for suits filed against

a state defendant. The AG first urges La.R.S. 13:5107(A)(2) and (D)(2) require

Ms. Thibodeaux’s suit be dismissed without prejudice because she did not request

service of citation and process on McNeese through the Board of Supervisors, him,

and the Office of Risk Management (ORM). Counsel for the AG admitted at the

2 hearing on the exceptions, Ms. Thibodeaux properly requested and obtained

service on McNeese.

Louisiana Revised Statutes 13:5107 (emphasis added) states, in pertinent

part:

(A)(1) In all suits filed against the state of Louisiana or a state agency, citation and service may be obtained by citation and service on the attorney general of Louisiana, or on any employee in his office above the age of sixteen years, or any other proper officer or person, depending upon the identity of the named defendant and in accordance with the laws of this state, and on the department, board, commission, or agency head or person, depending upon the identity of the named defendant and in accordance with the laws of this state, and on the department, board, commission, or agency head or person, depending upon the identity of the named defendant and the identity of the named board, commission, department, agency, or officer through which or through whom suit is to be filed against.

(2) Service shall be requested upon the attorney general within ninety days of filing suit. This shall be sufficient to comply with the requirements of Subsection D of this Section and also Code of Civil Procedure Article 1201(C). However, the duty of the defendant served through the attorney general to answer the suit or file other responsive pleadings does not commence to run until the additional service required upon the department, board, commission, or agency head has been made.

....

D. (1) In all suits in which the state, a state agency, or political subdivision, or any officer or employee thereof is named as a party, service of citation shall be requested within ninety days of the commencement of the action or the filing of a supplemental or amended petition which initially names the state, a state agency, or political subdivision or any officer or employee thereof as a party. This requirement may be expressly waived by the defendant in such action by any written waiver. If not waived, a request for service of citation upon the defendant shall be considered timely if requested on the defendant within the time period provided by this Section, notwithstanding insufficient or erroneous service.

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Bluebook (online)
Shandi Thibodeaux v. McNeese State University, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shandi-thibodeaux-v-mcneese-state-university-lactapp-2023.