Southern Environmental Management and Specialties, Inc. v. City of New Orleans and Honorable Latoya Cantrell, in Her Official Capacity as the Mayor of the City of New Orleans and Command Construction Industries, LLC and Arch Specialty Insurance, Inc.

CourtLouisiana Court of Appeal
DecidedMay 11, 2022
Docket2022-CA-0018
StatusPublished

This text of Southern Environmental Management and Specialties, Inc. v. City of New Orleans and Honorable Latoya Cantrell, in Her Official Capacity as the Mayor of the City of New Orleans and Command Construction Industries, LLC and Arch Specialty Insurance, Inc. (Southern Environmental Management and Specialties, Inc. v. City of New Orleans and Honorable Latoya Cantrell, in Her Official Capacity as the Mayor of the City of New Orleans and Command Construction Industries, LLC and Arch Specialty Insurance, Inc.) 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
Southern Environmental Management and Specialties, Inc. v. City of New Orleans and Honorable Latoya Cantrell, in Her Official Capacity as the Mayor of the City of New Orleans and Command Construction Industries, LLC and Arch Specialty Insurance, Inc., (La. Ct. App. 2022).

Opinion

SOUTHERN NO. 2022-CA-0018 ENVIRONMENTAL * MANAGEMENT AND SPECIALTIES, INC. * COURT OF APPEAL

VERSUS * FOURTH CIRCUIT

CITY OF NEW ORLEANS AND * STATE OF LOUISIANA HONORABLE LATOYA CANTRELL, IN HER ******* OFFICIAL CAPACITY AS THE MAYOR OF THE CITY OF NEW ORLEANS AND COMMAND CONSTRUCTION INDUSTRIES, LLC AND ARCH SPECIALTY INSURANCE, INC.

APPEAL FROM CIVIL DISTRICT COURT, ORLEANS PARISH NO. 2020-02242, DIVISION “E” Honorable Omar Mason, Judge ****** Judge Rosemary Ledet ****** (Court composed of Chief Judge Terri F. Love, Judge Rosemary Ledet, Pro Tempore Judge Madeline Jasmine)

Jonathan S. Forester Christopher K. LeMieux Evian Mugrabi RIESS LeMIEUX, LLC 1100 Poydras Street, Ste. 1100 New Orleans, LA 70163

COUNSEL FOR PLAINTIFF/APPELLANT

Craig N. Mangum Elliott Scharfenberg Audrey E. Martin KREBS FARLEY & DRY, PLLC 400 Poydras Street, Suite 2500 New Orleans, LA 70130

COUNSEL FOR DEFENDANT/APPELLEE AFFIRMED May 11, 2022 RML This is a construction project, nonpayment dispute. The plaintiff—Southern TFL Environmental Management and Specialties, Inc. (“SEMS”)—was a subcontractor MJ on a Louisiana Public Works Act (“LPWA”) project—the Hagan-Lafitte Drainage

Upgrades and Green Infrastructure Project (the “Project”).1 SEMS sued, among

others, the Project’s statutory surety—Arch Insurance Company (“Arch”)—

asserting two claims: a payment claim under the bond (“Payment Claim”); and an

insurance bad faith penalties claim under La. R.S. 22:1892 and 22:1973 (“Penalties

Claim”). On Arch’s motion for partial summary judgment, the trial court dismissed

SEMS’s Penalties Claim.2 SEMS appeals.

The sole question presented is a legal one: whether a surety that issues a

statutory bond under the LPWA is immune from insurance bad faith penalties

1 The LPWA—La. R.S. 38:2241, et seq.—governs public work contracts and requires that

governing authorities entering into a construction contract for a public work furnish a statutory bond. It is undisputed that the Project falls within the ambit of a public work regulated by the LPWA. 2 As discussed elsewhere in this opinion, the trial court, in a separate judgment, granted SEMS’s

summary judgment motion on SEMS’s Payment Claim; the trial court’s ruling on the Payment Claim is not before us on appeal.

1 under La. R.S. 22:1892 and 22:1973. Answering that question in the affirmative,

we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

This dispute originated from a public works project. The four parties

involved in this dispute are as follows: (i) the City of New Orleans, as Project

owner; (ii) Command Construction Industries, LLC (“Command”), as general

contractor; (iii) SEMS, as subcontractor; and (iv) Arch, as surety.3

In October 2018, the City entered into a bid contract for the Project with

Command—the lowest, responsible bidder. Command, in turn, subcontracted with

SEMS to perform a portion of the work on the Project. In connection with the

Project, Arch provided Command’s required statutory bond with Command as

principal, Arch as surety, and SEMS as obligee.4 During the Project, Command

asked SEMS to perform additional work on the Project.

Thereafter, a dispute arose over the timing and propriety of the amount owed

by Command to SEMS for work on the Project. When SEMS invoiced Command

for the work, Command paid a portion of the invoiced amount but disputed the

remaining balance that SEMS claimed was due. Seeking to recover the remaining

balance, SEMS took three steps. First, in November 2019, SEMS notified Arch

that it was making a payment claim under the bond for the remaining balance

claimed due.5 Second, in March 2020, SEMS recorded a statement of claim (a lien)

3 Although all four of these parties are named in the underlying lawsuit, this appeal involves only

SEMS, as appellant, and Arch, as appellee. 4 The bond obligated Arch to pay all sums due and owed to subcontractors for the Project.

5 In November 2019, SEMS submitted a claim under the payment bond for its claims for

extra-contractual quantity and unit price increases to its scope of work.

2 with the Orleans Parish Recorder of Mortgages. Third, also in March 2020, SEMS

sued, among others, Arch asserting the Payment Claim and the Penalties Claim.

SEMS filed a motion for summary judgment, seeking a judgment against

Arch on both the Payment Claim and the Penalties Claim. Arch, in response,

opposed the motion, in general, and filed a cross motion for partial summary

judgment as to the Penalties Claim, in particular. Triggered by a consent agreement

between the parties, the trial court bifurcated the summary judgment hearing and

separately heard and decided the Payment Claim and the Penalties Claim.

In July 2021, the trial court held a hearing on the Payment Claim. At that

hearing, the trial court orally granted SEMS’s motion, ruling in SEMS’s favor and

against Arch as to the Payment Claim.6 The following month, in August 2021, the

trial court held a hearing on the parties’ cross summary judgment motions on the

Penalties Claim. Following the hearing, the trial court, in October 2021, rendered a

written judgment granting Arch’s motion and denying SEMS’s motion.

In its October 2021 judgment, the trial court stated that, pursuant to the

LPWA (La. R.S. 38:2241, et seq.), SEMS has no claims as a matter of law for

relief under the Insurance Code; thus, the trial court dismissed with prejudice

SEMS’s claims against Arch under La. R.S. 22:1982 and 22:1973—the Penalties

Claim.7 This appeal by SEMS followed.

6 As discussed elsewhere in this opinion, the trial court, on this court’s order, supplemented the

record on appeal with a signed, written judgment granting SEMS’s summary judgment on the Payment Claim. In that judgment, the trial court ordered that “ARCH shall pay SEMS its contract balance, including retainage, and payment for extra work under the contract between [Command] and SEMS in the total amount of $219,730.45, as bifurcated and prayed for, for the reasons provided in open court.” 7 The trial court also denied SEMS’s summary judgment motion as to its Penalties Claim. In so

doing, the trial court held that SEMS has no claim, as a matter of law, for relief under the Insurance Code against Arch. Citing La. C.C.P. art. 966(A)(3), the trial court further held that material disputed facts exist and SEMS’s summary judgment motion for bad faith claims under

3 DISCUSSION

Standard of Review

The same standard of review applies to an appellate court’s review of a trial

court’s ruling on a summary judgment motion and a trial court’s determination of a

legal issue—the de novo standard. See Elliott v. Cont’l Cas. Co., 06-1505, p. 10

(La. 2/22/07), 949 So.2d 1247, 1253 (observing that “appellate courts review

summary judgments de novo under the same criteria that govern the district court’s

consideration of whether summary judgment is appropriate”;8 Pierce Foundations,

Inc. v. Jaroy Const., Inc., 15-0785, p. 7 (La. 5/3/16), 190 So.3d 298, 303

(“Pierce”) (observing that “[b]ecause this matter involves the interpretation of

statutory provisions and only questions of law are presented, review by this court is

de novo”). Moreover, “because the case involves the [LPWA], it must be strictly

construed.” Id.

Jurisdictional Issue

An appellate court has a duty to decide, regardless if a party raises the issue,

whether it has jurisdiction to consider the merits of an appeal. See Urquhart v.

Spencer, 15-1354, p. 3 (La. App. 4 Cir.

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Southern Environmental Management and Specialties, Inc. v. City of New Orleans and Honorable Latoya Cantrell, in Her Official Capacity as the Mayor of the City of New Orleans and Command Construction Industries, LLC and Arch Specialty Insurance, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/southern-environmental-management-and-specialties-inc-v-city-of-new-lactapp-2022.