Southern Shipbuilding Corp. v. Richardson

363 So. 2d 1329, 1978 La. App. LEXIS 3142
CourtLouisiana Court of Appeal
DecidedOctober 12, 1978
DocketNo. 9472
StatusPublished
Cited by3 cases

This text of 363 So. 2d 1329 (Southern Shipbuilding Corp. v. Richardson) 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 Shipbuilding Corp. v. Richardson, 363 So. 2d 1329, 1978 La. App. LEXIS 3142 (La. Ct. App. 1978).

Opinion

GARRISON, Judge.

This suit is an appeal from a concursus proceeding arising out of litigation between Jeri Lynn Richardson, individually and as natural tutrix of her minor children, against Southern Shipbuilding Corporation and its insurer for the wrongful death of Brand Richardson, her husband. Mrs. Richardson’s suit was settled prior to trial for the amount of $275,000. However, a dispute arose between her and her attorneys (Milton Brener, John Robbert, and Garon, Brener & McNeely) as to the amount of attorney’s fees to be deducted from the settlement funds. Accordingly, Southern Shipbuilding filed this concursus proceeding and deposited the settlement funds in the registry of the court.

The defendant attorneys answered the petition for concursus, alleging that they had a contract and agreement with Mrs. Richardson on behalf of herself and her minor children to pursue the wrongful death claim and that the agreed fee was to be one-third of the recovery ($275,000 X V3 = $91,666.67) whether by settlement or by judgment after trial, costs to be paid by Mrs. Richardson.

Mrs. Richardson’s answer to the concur-sus petition, on the other hand, set forth a claim against the defendant attorneys, alleging that there was never a mutual understanding or meeting of the minds between Mrs. Richardson and the attorneys concerning the fee for representing her; that at the time of execution of the alleged contract she did not have legal authority to contract a fee agreement on behalf of her [1331]*1331minor children, and that she never contracted such an agreement on their behalf; that the defendant attorneys are entitled to quantum meruit fee only, in an amount not to exceed $10,000, from Mrs. Richardson’s portion of the settlement funds, and are not entitled to any fee from the children’s portions of the settlement funds (alternatively, that if the attorneys are entitled to a fee from the children’s portions of the settlement funds, that the fees should be based on quantum meruit, not to exceed $5,000 per child).

Subsequently, Mrs. Richardson was allowed to withdraw the settlement funds above the disputed amount, leaving the amount of $92,403.33 on deposit, which was the amount of the fee claimed by the attorneys ($91,666.67) plus costs expended by them ($736.76).

The attorneys filed a motion for summary judgment, which was denied, and the matter proceeded to trial.

After trial on the merits, judgment was rendered in favor of the attorneys in the amount of $91,667.00. Mrs. Richardson moved for a new trial, as did the defendant attorneys (who contended that the judgment in their favor should have been in the amount of $92,403.76, the amount of their fee plus costs expended by them). The motions were denied, and Mrs. Richardson filed an appeal. The defendant attorneys have answered the appeal, claiming that the judgment of the lower court should be amended to include the amount of the costs expended by them.

Mrs. Richardson specifies the following errors on appeal:

(1) That the court erred in finding that the contingent fee contract was valid on behalf of the two minor children;

(2) That the court erred in finding the contract valid as to Mrs. Richardson individually, because the contract was vague and ambiguous, did not conform with R.S. 37— 218, and there was no “meeting of the minds”; and

(3) That the court erred in allowing the defendant attorneys to introduce evidence as to quantum meruit when they failed to plead the same specifically.

First, as to Mrs. Richardson’s right to sign the contract on behalf of the children, Mrs. Richardson cites Code of Civil Procedure Articles 40611 and 41712 as the bases for her contention that she had no authority to sign the contract because she had not yet taken an oath as tutrix. It should be noted that neither of these articles, nor C.C.P. Art. 4271,3 upon which she also relies, makes any specific reference to the entering into of binding contracts on behalf of a minor. On the contrary, only references to “official duties,” in the broadest sense, are made. She further cites several cases in support of her contention.

Assuming, arguendo, that an unconfirmed natural tutrix does not have the authority to sign such a contract on behalf of her minor children, we must look at the practical as well as the legal aspects of the matter. According to the expert witnesses, Mr. Russ Herman and Mr. Wilfred Bou-[1332]*1332dreaux, because the law requires court approval of all actions affecting a minor’s interest, the usual procedure in settling claims on behalf of minors is to include a stipulation in the court’s judgment regarding the amount of the attorney’s fee. At the same time, apparently it is seldom that an attorney prosecuting a wrongful death claim such as this one will have the surviving parent judicially confirmed as natural tutor/tutrix until immediately preceding settlement of the case, unless such confirmation is necessary for other purposes. Thus, the situation in this case is common to a very large number of similar cases: that is, a surviving spouse prosecutes a claim on behalf of his or her minor children by signing a contingent fee contract with an attorney, for a usual fee of one-third of recovery, without that parent having been legally authorized as the minor’s tutor as required by Articles 4061 and 4171 of the Code of Civil Procedure.

The question is whether, considering the exigencies of the situation, a natural tutor/tutrix is required to be judicially confirmed prior to signing a contingent fee contract on behalf of a minor. If the natural tutor may sign such a contract only after his confirmation by the court, this requirement would have a far-reaching effect on present practices of attorneys in this locale regarding their employment on wrongful death claims. Further, it creates a tension between the mandates of the Civil Code and Code of Civil Procedure provisions regarding tutorship (the clear intent of which is to insure that all actions on a minor’s behalf be taken under color of court authority) and the holding in Cacibauda v. Gaiennie, 305 So.2d 572 (La.App. 4th Cir. 1974), which emphasizes the natural obligation of a mother to administer the minor’s estate until she causes the appointment of a tutor. However, as the court in Cacibauda stated,

“The spirit of this [C.C.P. Art. 4061] and other laws governing the rights of minors have for their purpose the conservation of the minor’s estate and the establishment of a form of security from which he can be reimbursed if his assets have been dissipated before he attains majority.” 305 So.2d at 583.

Thus, it seems clear that the mother’s obligation to conserve the minor’s estate should prevail over the technical requirements of the Code of Civil Procedure, except in cases of clear abuse. See also, Caruthers v. U. S. Safety Deposit & Savings Bank, 8 Orl.App. 93 (1910).4

Furthermore, as noted above, neither the Civil Code nor the Code of Civil Procedure contains any specific requirement that a natural tutor must obtain prior judicial approval of any contract, including those for attorneys’ services. The only law that appellant has been able to cite in support of this position is the case of Garden Hill Land Corp. v. Succession of Cambre, 306 So.2d 718 (La.1975).

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Related

In Re Tutorship of Ingraham
565 So. 2d 1012 (Louisiana Court of Appeal, 1990)
Guidry v. Rubin
425 So. 2d 366 (Louisiana Court of Appeal, 1982)
Southern Shipbuilding Corp. v. Richardson
366 So. 2d 571 (Supreme Court of Louisiana, 1979)

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Bluebook (online)
363 So. 2d 1329, 1978 La. App. LEXIS 3142, Counsel Stack Legal Research, https://law.counselstack.com/opinion/southern-shipbuilding-corp-v-richardson-lactapp-1978.