Shelly Benoit v. City of Lake Charles

CourtLouisiana Court of Appeal
DecidedJuly 20, 2005
DocketCW-0005-0089
StatusUnknown

This text of Shelly Benoit v. City of Lake Charles (Shelly Benoit v. City of Lake Charles) 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
Shelly Benoit v. City of Lake Charles, (La. Ct. App. 2005).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

CW05-89

SHELLY BENOIT

VERSUS

CITY OF LAKE CHARLES, UNITED STATES SPECIALTY SPORTS ASSOCIATION AND UNITED STATES NATIONAL INSURANCE COMPANY

**********

ON APPLICATION FOR SUPERVISORY WRITS FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 02-4508 HONORABLE WILFORD CARTER, DISTRICT JUDGE

MARC T. AMY JUDGE

Court composed of Ulysses Gene Thibodeaux, Chief Judge, John D. Saunders, Marc T. Amy, Michael G. Sullivan, and Elizabeth A. Pickett, Judges.

WRIT GRANTED IN PART AND MADE PEREMPTORY; WRIT DENIED IN PART; REMANDED.

Thibodeaux, C.J., dissents in part and assigns written reasons. Saunders, J., concurs in part, dissents in part, and assigns reasons.

H. Alan McCall Stockwell, Sievert, Viccellio, Clements & Shaddock, L.L.P. Post Office Box 2900 Lake Charles, LA 70602 (337) 436-9491 COUNSEL FOR DEFENDANTS/APPLICANTS: City of Lake Charles United National Insurance Company United States Specialty Sports Association Jeffrey T. Gaughan Baggett, McCall, Burgess, Watson & Gaughan 3006 Country Club Road Lake Charles, LA 70605 (337) 478-8888 COUNSEL FOR PLAINTIFF/RESPONDENT: Shelly Benoit AMY, Judge.

The plaintiff seeks damages related to a fall occurring at a ballpark owned by

the City of Lake Charles. The defendants filed a motion for summary judgment,

asserting immunity pursuant to La.R.S. 9:2795. The trial court denied the motion.

The defendants filed the instant writ application. For the following reasons, we grant

in part, deny in part and remand for further proceedings.

Factual and Procedural Background

The plaintiff, Shelly Benoit, alleges that she fractured her ankle after she

stepped into a depressed portion of the ground at a park and ballfield owned by the

City of Lake Charles. Mrs. Benoit and her family were visiting the park on that day

to attend a baseball tournament in which her son was participating. The City of Lake

Charles and the United States Specialty Sports Association (USSSA), the

organization allegedly hosting and organizing the tournament, were named as

defendants as was USSSA’s insurer, United National Insurance Company.

The defendants filed a motion for summary judgment, asserting the

applicability of recreational immunity under La.R.S. 9:2795. The motion was denied

by the trial court.

Discussion

The defendants question the trial court’s determination that genuine issues of

material fact remain with regard to who was responsible for creating the depressed

area on the park property. The defendants contend that such a determination is

irrelevant as La.R.S. 9:2795 does not include the condition’s origin as a factor in

determining the applicability of the recreational immunity statute. The plaintiff

contends that La.R.S. 9:2795 is inapplicable in the present case as the injury did not occur in a “true outdoors” setting, but instead, occurred on a ballfield in a developed

city park.

On appeal, a trial court’s ruling on a motion for summary judgment is reviewed

pursuant to the de novo standard of review. Champagne v. Ward, 03-3211 (La.

1/19/05), 893 So.2d 773. Accordingly, we consider the standard set forth in La.Code

Civ.P. art. 966. Subsection B of that provision requires that summary judgment shall

be rendered “if the pleadings, depositions, answers to interrogatories, and admissions

on file, together with the affidavits, if any, show that there is no genuine issue as to

material fact, and that mover is entitled to judgment as a matter of law.”

The immunity provision in this case is La.R.S. 9:2795, which provides:

§ 2795. Limitation of liability of landowner of property used for recreational purposes; property owned by the Department of Wildlife and Fisheries; parks owned by public entities

A. As used in this Section:

(1) “Land” means urban or rural land, roads, water, watercourses, private ways or buildings, structures, and machinery or equipment when attached to the realty.

(2) “Owner” means the possessor of a fee interest, a tenant, lessee, occupant or person in control of the premises.

(3) “Recreational purposes” includes but is not limited to any of the following, or any combination thereof: hunting, fishing, trapping, swimming, boating, camping, picnicking, hiking, horseback riding, bicycle riding, motorized, or nonmotorized vehicle operation for recreation purposes, nature study, water skiing, ice skating, roller skating, roller blading, skate boarding, sledding, snowmobiling, snow skiing, summer and winter sports, or viewing or enjoying historical, archaeological, scenic, or scientific sites.

(4) “Charge” means the admission price or fee asked in return for permission to use lands.

(5) “Person” means individuals regardless of age.

2 B. (1) Except for willful or malicious failure to warn against a dangerous condition, use, structure, or activity, an owner of land, except an owner of commercial recreational developments or facilities, who permits with or without charge any person to use his land for recreational purposes as herein defined does not thereby:

(a) Extend any assurance that the premises are safe for any purposes.

(b) Constitute such person the legal status of an invitee or licensee to whom a duty of care is owed.

(c) Incur liability for any injury to person or property caused by any defect in the land regardless of whether naturally occurring or man-made.

(2) The provisions of this Subsection shall apply to owners of commercial recreational developments or facilities for injury to persons or property arising out of the commercial recreational activity permitted at the recreational development or facility that occurs on land which does not comprise the commercial recreational development or facility and over which the owner has no control when the recreational activity commences, occurs, or terminates on the commercial recreational development or facility.

C. Unless otherwise agreed in writing, the provisions of Subsection B shall be deemed applicable to the duties and liability of an owner of land leased for recreational purposes to the federal government or any state or political subdivision thereof or private persons.

D. Nothing in this Section shall be construed to relieve any person using the land of another for recreational purposes from any obligation which he may have in the absence of this Section to exercise care in his use of such land and in his activities thereon, or from the legal consequences of failure to employ such care.

E. (1) The limitation of liability provided in this Section shall apply to any lands or water bottoms owned, leased, or managed by the Department of Wildlife and Fisheries, regardless of the purposes for which the land or water bottoms are used, and whether they are used for recreational or nonrecreational purposes.

(2)(a) The limitation of liability provided in this Section shall apply to any lands, whether urban or rural, which are owned, leased, or managed as a public park by the state or any of its political subdivisions and which are used for recreational purposes.

3 (b) The provision of supervision on any land managed as a public park by the state or any of its political subdivisions does not create any greater duty of care which may exist and does not create a duty of care or basis of liability for personal injury or for damage to personal property caused by the act or omission of any person responsible for security or supervision of park activities, except as provided in Subparagraph (E)(2)(d) of this Section.

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