Stuart Services, L.L.C. Versus Nash Heating & Air Conditioning, Inc. and Ronnie Camet

CourtLouisiana Court of Appeal
DecidedDecember 7, 2022
Docket22-CA-105
StatusUnknown

This text of Stuart Services, L.L.C. Versus Nash Heating & Air Conditioning, Inc. and Ronnie Camet (Stuart Services, L.L.C. Versus Nash Heating & Air Conditioning, Inc. and Ronnie Camet) 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
Stuart Services, L.L.C. Versus Nash Heating & Air Conditioning, Inc. and Ronnie Camet, (La. Ct. App. 2022).

Opinion

STUART SERVICES, L.L.C. NO. 22-CA-105

VERSUS FIFTH CIRCUIT

NASH HEATING & AIR CONDITIONING, COURT OF APPEAL INC. AND RONNIE CAMET STATE OF LOUISIANA

ON APPEAL FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT PARISH OF JEFFERSON, STATE OF LOUISIANA NO. 707-856, DIVISION "G" HONORABLE E. ADRIAN ADAMS, JUDGE PRESIDING

December 07, 2022

JOHN J. MOLAISON, JR. JUDGE

Panel composed of Judges Fredericka Homberg Wicker, Robert A. Chaisson, and John J. Molaison, Jr.

AMENDED; AFFIRMED AS AMENDED; REMANDED JJM FHW RAC COUNSEL FOR PLAINTIFF/APPELLANT, STUART SERVICES, LLC Raymond B. Landry John F. Lee Thomas M. Flanagan Camille E. Gauthier Alixe Duplechain Leonard L. Levenson Christian W. Helmke Colleen B. Gannon Donna R. Barrios

COUNSEL FOR DEFENDANT/APPELLEE, RONNIE CAMET T. Randolph Richardson Thomas J. Barbera MOLAISON, J.

Appellant, Stuart Services, L.L.C, seeks review of the trial court’s judgment

which declined to award damages resulting from the breach of an employment

agreement, and further awarded costs and attorneys’ fees to the appellee, Ronnie

Camet. Mr. Camet has filed an answer and seeks additional attorneys’ fees

incurred in connection with the appeal as well as the trial court proceedings. For

the reasons that follow, the judgment of the trial court is amended in part and

affirmed as amended. Mr. Camet’s answer to the appeal is granted, in part. We

further remand the matter for additional proceedings related to the calculation of

Mr. Camet’s attorneys’ fees.

FACTUAL SUMMARY AND PROCEDURAL HISTORY

On February 8, 2008, Mr. Camet sold the “goodwill,” client list,1 and the

name of his business, “R.C. Camet Air Conditioning” to Stuart Services, L.L.C

(“Stuart”) for the sum of $60,000. In tandem with the sale, Mr. Camet entered into

an employment agreement with Stuart which provided, in relevant parts, that Mr.

Camet would become an employee for Stuart and his duties would fall “primarily

in the capacity of a salesperson,” and that he would also serve as a liaison between

his former customers and Stuart. The term for the employment agreement specified

that it would be effective from January 1, 2008 until December 31, 2009, unless

sooner terminated. The agreement also specified that Mr. Camet could not engage

in a business similar to Stuart, and could not solicit Stuart’s customers, for a period

of two years following his termination. Mr. Camet subsequently worked for Stuart

until November 1, 2009. After leaving employment there, Mr. Camet

unsuccessfully sought to negotiate a change in terms of the noncompetition

1 While the agreement refers to a “client list” generically, no specific clients of Mr. Camet’s former business were named.

22-CA-105 1 agreement. In February, 2010, Mr. Camet began working for Nash Heating & Air

Conditioning, (“Nash”).

On October 31, 2011, Stuart filed a petition for damages at the Twenty-

Fourth Judicial District Court which alleged that Mr. Camet had violated the non-

competition term of their employment agreement when he accepted a position with

Nash, which was engaged in a similar business as Stuart.2 The petition also alleged

that Mr. Camet had actively pursued, within an unidentified time frame, three of

his former accounts3 and took their business away from Stuart, in violation of the

Louisiana Unfair Trade Practices Act.

On February 23, 2014, Stuart filed a motion for partial summary judgment

on the issue of whether Mr. Camet had breached the 2008 employment agreement.

On June 19, 2014, the trial court granted Stuart’s motion for partial summary

judgment and found that Mr. Camet had failed to fulfill his obligations under the

employment agreement with Stuart.4 In the same order, the trial court provided

that “the issue of the damages for which Camet is liable to Stuart is reserved for

future resolution.”5

A judge trial on the issue of damages was eventually held on March 1 and 3,

2021. In its judgment dated April 23, 2021, the trial court ruled in favor of Mr.

2 Stuart’s petition alleged that Mr. Camet and Nash were liable for damages in solido; however, Nash was dismissed from the lawsuit pursuant to a joint motion granted on March 18, 2014. 3 The accounts identified by name in Stuart’s petition for damages were the St. Ann School and Church, the St. Clement of Rome School and Church, and Guaranty Savings Bank. 4 The trial court specifically found that Mr. Camet “breached the employment agreement” but reserved the issue of damages for future trial. As explained in the 1984 Revision Comments to Louisiana Civil Code Article 1994 cited infra, the word “breach” was replaced by “failure to perform”. As explained by Litanoff in the Louisiana Civil Law Treatise, the term “breach” was deliberately removed from the Civil Code during the 1984 revisions; “…the expression defective performance, rather than breach of one kind or another, conveys with greater clarity the idea of a performance rendered in an unsatisfactory manner.” (Emphasis original.) The Law of Obligations: Putting in Default and Damages, 2.18. With this in mind, we endeavor in this opinion to use the correct terminology while still recognizing the merits of parties’ arguments. 5 It does not appear that either Mr. Camet or Nash sought review of the trial court’s ruling on the motion for partial summary judgment at that time.

22-CA-105 2 Camet, and dismissed all of Stuart’s claims against him with prejudice. The trial

court further indicated that pursuant to “Provision 5.4 of the Employment

Agreement and Provision 6.8 of the Sales Agreement,” Mr. Camet, as the

prevailing party, was entitled to collect reasonable expenses and attorneys’ fees.

Mr. Camet’s motion to tax costs and expenses was heard on August 13,

2021, and, on September 27, 2021, the trial court awarded Mr. Camet $3,873.60 in

costs, in addition to $86,536.75 in attorneys’ fees. This appeal by Stuart followed.

Mr. Camet has answered the appeal and requests attorneys’ fees incurred in

connection with his opposition to Stuart’s appeal and his motion to tax costs, as

well as additional costs not awarded by the trial court.

ASSIGMENTS OF ERROR

1. The district court erred in admitting a hearsay letter into evidence under the business records exception; that letter was not properly authenticated as a business record of either the author or recipient.

2. The district court erred in dismissing Stuart’s claims and finding that it suffered no damages as a result of Camet’s breach of the noncompetition provision.

3. The district court erred in allowing Camet, who breached the employment agreement, to enforce the contract and collect attorney’s fees and costs, including those incurred for issues on which Camet lost.

LAW AND ANALYSIS

ASSIGNMENT OF ERROR ONE

In its first assignment of error, Stuart asserts that that trial court erred in

admitting one of Mr. Camet’s exhibits6 into evidence at trial, a letter from Francis

Minor, a former business manager for St. Clement of Rome, which purportedly

explains why St. Clement no longer did business with Stuart.7 At trial, Stuart

6 The exhibit at issue is identified as “Defense Exhibit-11.” The record shows that Mr. Camet initially identified the letter as “Exhibit 13” in the joint pre-trial order filed by the parties on February 22, 2021. 7 Among the reasons provided by the author of the letter were Stuart’s billing errors and Stuart’s rates being higher than those of competitors.

22-CA-105 3 timely objected to the letter as hearsay. Counsel for Mr.

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Stuart Services, L.L.C. Versus Nash Heating & Air Conditioning, Inc. and Ronnie Camet, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stuart-services-llc-versus-nash-heating-air-conditioning-inc-and-lactapp-2022.