Theodule P. Noel, Jr. v. Theodule P. Noel, Sr.

CourtLouisiana Court of Appeal
DecidedFebruary 16, 2022
DocketCA-0021-0497
StatusUnknown

This text of Theodule P. Noel, Jr. v. Theodule P. Noel, Sr. (Theodule P. Noel, Jr. v. Theodule P. Noel, Sr.) 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
Theodule P. Noel, Jr. v. Theodule P. Noel, Sr., (La. Ct. App. 2022).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

21-497

THEODULE P. NOEL, JR., ET AL.

VERSUS

THEODULE P. NOEL, SR., ET AL.

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF VERMILION, NO. 96657 HONORABLE THOMAS R. DUPLANTIER, DISTRICT JUDGE

SHANNON J. GREMILLION JUDGE

Court composed of Shannon J. Gremillion, Candyce G. Perret, and J. Larry Vidrine, * Judges.

EXCEPTIONS DENIED. AFFIRMED IN PART AND REVERSED IN PART, AND REMANDED.

Ralph Edward Kraft Kraft Lege, LLC 600 Jefferson Street, Suite 410 Lafayette, LA 70501 (337) 706-1818 COUNSEL FOR PLAINTIFFS/APPELLANTS: Theodule P. Noel, Jr. Christine Noel Devenport

* The Honorable J. Larry Vidrine participates by appointment of the Louisiana Supreme Court as judge pro tempore. Thomas J. Gayle Gayle Law Firm, LLC 713 Kirby Street Lake Charles, LA 70601 (337) 494-1220 COUNSEL FOR PLAINTIFFS/APPELLANTS: Theodule P. Noel, Jr. Christine Noel Devenport

R. Chadwick Edwards, Jr. Edwards & Edwards, LLC P.O. Box 217 Abbeville, LA 70511-0217 (337) 893-2884 COUNSEL FOR DEFENDANTS/APPELLEES: Samuel Noel, individually and as Independent Executor of the Succession of Theodule P. Noel, Sr. Pamela A. Noel GREMILLION, Judge.

Plaintiffs, Theodule P. Noel, Jr. (Ted) and Christine Noel Devenport, appeal

the summary judgment in favor of defendants, Samuel J. Noel, individually and as

executor of the Succession of Theodule P. Noel, Sr., and Pamela A. Noel, on several

causes of action and issues in the above daptioned matter. Defendants answered the

appeal asserting exceptions and seeking review of the trial court’s denial of summary

judgment on certain issues. For the reasons that follow, we deny defendants’

exceptions, affirm the trial court in part, reverse in part, and remand for further

proceedings.

FACTS, HISTORY, AND PROCEDURAL POSTURE

The essential facts of this matter are summarized in Noel v. Noel, 15-37, pp.

2-5 (La.App. 3 Cir. 5/27/15), 165 So.3d 401, 406-08, writ denied vel nom, Noel, Jr.

v. Noel, Sr., 15-1121 (La. 9/18/15), 178 So.3d 147:

The allegations made by both parties to this suit center around a power of attorney[1] executed in 2006 and the sales of properties pursuant to that instrument. Mrs. Irene Joyce Trahan Noel (“Mrs. Noel”), now deceased, and Mr. Theodule P. Noel, Sr. (“Mr. Noel”) were married and had four children of the marriage: Theodule P. Noel, Jr., Christine Noel Devenport, Catherine A. Noel, and Samuel J. Noel. Mr. and Mrs. Noel prepared last wills and testaments in 2005. Those documents established that Theodule Noel, Jr., Christine Devenport, and Catherine Noel were to receive certain parcels of property according to Mrs. Noel’s will, while Samuel Noel would receive property according to Mr. Noel’s will. Mrs. Noel allegedly executed a power of attorney, dated January 12, 2006, purportedly giving her son, Samuel Noel, authority to conduct various acts on her behalf, including the sale and transfer of property. In addition to their wills, Mr. and Mrs. Noel had previously made several inter vivos donations of property to their children, then executed farm lease agreements related to those properties, which established their children as lessors and Mr. and Mrs. Noel as lessees.

In 2007, Mrs. Noel suffered a stroke, after which her health steadily declined. The parties disagree about the status of Mrs. Noel’s [1] Pursuant to La.Civ.Code art. 2989, a “power of attorney” is known in Louisiana as a “mandate,” “a contract by which a person, the principal, confers authority on another person, the mandatary, to transact one or more affairs for the principal.” For simplicity and consistency, we will refer to Mrs. Noel’s mandate as a power of attorney. health prior to her stroke. However, Appellants allege that beginning in December 2005, Mrs. Noel began experiencing a mental decline, which was exhibited by confusion, lack of awareness and memory, as well as her continual inability to dress and bathe herself. Appellants filed a petition for interdiction of Mrs. Noel on May 9, 2011. Service was not effectuated on Mrs. Noel within the requisite time and the proceedings were not advanced.

Between 2008 and 2011, Samuel Noel, via power of attorney, and Mr. Noel executed several sales of Mr. and Mrs. Noel’s property. Those sales were made to Samuel Noel himself, his wife, Pamela Andrepont Noel, Ross Hebert, and Dr. Samuel Schuffler. The properties sold included those that Mrs. Noel had previously indicated in her will would be donated mortis causa to her other three children. Furthermore, Samuel Noel, via power of attorney, and Mr. Noel sublet the leased farm property belonging to Appellants to third parties, allegedly in contradiction of the lease agreement.

Mrs. Noel died on January 19, 2012. Her succession was opened on January 30, 2012, in a separate proceeding with Judge Marilyn Castle, but was not under administration. In that proceeding, Judge Castle appointed Catherine Noel as Executrix on April 8, 2013. Appellants initiated the current suit on January 15, 2013, to cancel the real estate transactions, alleging they were executed using an invalid power of attorney. Appellants asserted that the power of attorney could not have been signed on the day it is dated, as well as that Mrs. Noel lacked capacity at that time to sign a power of attorney. Appellants then filed a first supplemental and amended petition to cancel the farm leases for breach of the lease agreements, and to recover Farm Service Agency (FSA) payments and crop revenues. In his answer, Mr. Noel filed a reconventional demand seeking the revocation of inter vivos donations he made to Appellants between 1986 and 2003. Mr. Noel listed twelve acts of ingratitude committed by Appellants that he believed constituted cruel treatment and grievous injury sufficient to revoke the donations.

The trial court determined that plaintiffs had no right of action to bring the

suit and granted summary judgment in favor of Mr. Noel and the

defendants/appellees on the authenticity of the power of attorney. It further

dismissed Mr. Noel’s request to revoke the donations inter vivos. This court

affirmed in part, reversed in part, and remanded to the trial court for further

proceedings regarding the authenticity of the 2006 power of attorney, Mrs. Noel’s

capacity to execute the power of attorney, and the request to revoke the donations

inter vivos on the grounds of ingratitude based upon plaintiffs’ filing of the present 2 suit. Sometime after this opinion, Mr. Noel passed away. Noel v. Noel, 16-734

(La.App. 3 Cir. 8/2/17), 225 So.3d 1114, writs denied, 17-1817, 17-1839 (La.

1/9/18), 231 So.3d 651, and 17-130 (La. 1/9/18), 231 So.3d 654.

On remand, a trial was held solely on the issue of Mrs. Noel’s mental capacity

to execute the 2006 power of attorney. The trial court took the matter under

advisement and ruled that Mrs. Noel possessed requisite mental capacity to execute

the power of attorney, which, the trial court further ruled, authorized Samuel J. Noel

to sell Mrs. Noel’s property to himself. On appeal, this court held that neither the

2002 nor the 2006 powers of attorney authorized self-dealing on the mandatary’s

part. Noel, 225 So.3d 1114. Because the powers of attorney did not authorize self-

dealing, we further vacated on the grounds of mootness the trial court’s judgment

finding that Mrs. Noel possessed the capacity to execute the 2006 power of attorney.

Id. We remanded the matter for trial on the issues of “fraud, breach of fiduciary

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