Tony Barnes v. Reata L. West

CourtLouisiana Court of Appeal
DecidedFebruary 4, 2015
DocketCA-0014-1018
StatusUnknown

This text of Tony Barnes v. Reata L. West (Tony Barnes v. Reata L. West) 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
Tony Barnes v. Reata L. West, (La. Ct. App. 2015).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

14-1018

TONY BARNES, ET AL.

VERSUS

REATA L. WEST, ET AL.

**********

APPEAL FROM THE ALEXANDRIA CITY COURT PARISH OF RAPIDES, NO. 121,872 HONORABLE RICHARD E. STARLING, JR., CITY COURT JUDGE

MARC T. AMY JUDGE

Court composed of Jimmie C. Peters, Marc T. Amy, and Shannon J. Gremillion, Judges.

REVERSED.

Thomas B. Wahlder 1740 Jackson Street Alexandria, LA 71301 (318) 442-9417 COUNSEL FOR PLAINTIFFS/APPELLEES: Tony Barnes Keshela Woodland

Howell D. Jones, IV Post Office Box 14558 Alexandria, LA 71315 (318) 442-1515 COUNSEL FOR PLAINTIFFS/APPELLEES: Tony Barnes Keshela Woodland James M. Dill Simone C. Dupre The Dill Firm, A.P.L.C. Post Office Box 3324 Lafayette, LA 70502-3324 (337) 261-1408 COUNSEL FOR DEFENDANT/APPELLANT: Safeway Insurance Company of Louisiana AMY, Judge.

The plaintiffs in this automobile accident suit settled with the plaintiff/car-

owner’s uninsured motorist insurer. After the insurer allegedly failed to remit the

settlement funds within thirty days, the plaintiffs filed a motion for penalties. The

trial court granted the motion and imposed a $5,000.00 penalty. The insurer

appeals. For the following reasons, we reverse.

Factual and Procedural Background

The underlying claims in this matter arise from an automobile accident. The

plaintiffs’ vehicle was driven by Tony Barnes and owned by Shirley Cross, who

was also a passenger. In addition to Mr. Barnes and Ms. Cross, Keshela

Woodland,1 Destiny Woodland, Kimberly Miles, Antonio Barnes, Jazalyn Miles,

and Ja’Kayshia Miles were all passengers in the plaintiffs’ vehicle. The

defendant’s vehicle was driven by Reata West. According to the record, it was

eventually determined that the only applicable insurance coverage was Ms. Cross’

uninsured motorist coverage, which was issued by Safeway Insurance Company of

Louisiana. Thereafter, the plaintiffs reached an agreement with Safeway to settle

for policy limits.

However, the plaintiffs allege that Safeway failed to fund the settlement

within thirty days of the date that the agreement was put into writing, and that

Safeway is liable for penalties pursuant to La.R.S. 22:1973 as a result. Neither the

plaintiffs nor Safeway agree on the date that the settlement agreement was put into

writing. After a hearing, the trial court found that the agreement was confected on

March 18, 2013, and that Safeway acquiesced to that date. Accordingly, the trial

1 Keshela Woodland’s name is also spelled as “Kiesha” in the record. We use the spelling in the petition. court found that Safeway paid the settlement thirty-four days after the settlement

agreement was reduced to writing. Having made that determination, the trial court

assessed a penalty of $5,000.00 against Safeway pursuant to La.R.S.

22:1973(B)(2).

Safeway appeals. Although Safeway asserts no discrete assignments of

error, the crux of its argument is that the trial court erred in awarding penalties.

Further, in their brief, the plaintiffs request an increase in the penalties awarded.

Discussion

La.R.S. 22:1973(B)(2)

Pursuant to La.R.S. 22:1973,2 in relevant part:

A. An insurer, including but not limited to a foreign line and surplus line insurer, owes to his insured a duty of good faith and fair dealing. The insurer has an affirmative duty to adjust claims fairly and promptly and to make a reasonable effort to settle claims with the insured or the claimant, or both. Any insurer who breaches these duties shall be liable for any damages sustained as a result of the breach.

B. Any one of the following acts, if knowingly committed or performed by an insurer, constitutes a breach of the insurer’s duties imposed in Subsection A of this Section:

....

(2) Failing to pay a settlement within thirty days after an agreement is reduced to writing.

C. In addition to any general or special damages to which a claimant is entitled for breach of the imposed duty, the claimant may be awarded penalties assessed against the insurer in an amount not to exceed two times the damages sustained or five thousand dollars, whichever is greater. Such penalties, if awarded, shall not be used by the insurer in computing either past or prospective loss experience for the purpose of setting rates or making rate filings.

2 Former La.R.S. 22:1220 was renumbered as La.R.S. 22:1973 by 2008 La. Acts 415, §1, effective January 1, 2009.

2 Because it is penal in nature, La.R.S. 22:1973 is strictly construed. Reed v.

State Farm Mut. Auto. Ins. Co., 03-107 (La. 10/21/03), 857 So.2d 1012. When a

party seeks penalties as a result of an insurer’s failure to pay a settlement within

thirty days, the party need not prove that the insurer was “arbitrary, capricious, or

without probable cause” in failing to pay the settlement. Sultana Corp. v. Jewelers

Mut. Ins. Co., 03-360, p. 9 (La. 12/3/03), 860 So.2d 1112, 1119. Instead, the party

need only show that the insurer’s failure was “knowingly committed.” Id.

A settlement agreement is a compromise governed by Title XVII of Book III

of the Louisiana Civil Code. Holt v. Ace Amer. Ins. Co., 14-380 (La.App. 3 Cir.

10/1/14), 149 So.3d 886. “A compromise is a contract whereby the parties,

through concessions made by one or more of them, settle a dispute or an

uncertainty concerning an obligation or other legal relationship.” La.Civ.Code art.

3071. Additionally, “[a] compromise shall be made in writing or recited in open

court, in which case the recitation shall be susceptible of being transcribed from

the record of the proceedings.” La.Civ.Code art. 3072. “[T]he requirement that

the agreement be reduced to writing necessarily implies that the agreement be

evidenced by documentation signed by both parties.” Brasseaux v. Allstate Ins.

Co., 97-526, p. 5 (La.App. 1 Cir. 4/8/98), 710 So.2d 826, 829 (emphasis in

original). But see Speyrer v. Gray Ins. Co., 11-1154 (La.App. 3 Cir. 2/1/12), 83

So.3d 1231. We note that there is no requirement that a compromise be contained

in a single document. Brasseaux, 710 So.2d 826. In fact, where two instruments

outline the parties’ obligations to each other when read together and their

acquiescence to the agreement, a written compromise has been perfected. Id.

3 However, “[a] letter by one of the parties setting forth their understanding of the

agreement is not an agreement of the parties reduced to writing.” Id. at 829.

As the trial court determines the intent of the parties with regard to the

compromise, a trial court’s determination that a settlement was reduced to writing

is a finding of fact subject to the manifest error standard of review. Holt, 149

So.3d 886.

The plaintiffs assert that a settlement was reached and put into writing on

March 18, 2013. Safeway objects to this date and contends that the settlement was

put into writing on April 5, 2013. It is undisputed that Safeway did not tender the

settlement funds until April 22, 2013. Pursuant to La.R.S. 22:1973(B)(2), if the

settlement was put into writing on March 18, 2013, Safeway’s payment was

untimely. However, if it was put into writing on April 5, 2013, the payment was

within the thirty-day time period, and Safeway would not be liable for penalties

under that provision.

The record contains the following evidence concerning the settlement. On

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Related

Brasseaux v. Allstate Ins. Co.
710 So. 2d 826 (Louisiana Court of Appeal, 1998)
Reed v. State Farm Mut. Auto. Ins. Co.
857 So. 2d 1012 (Supreme Court of Louisiana, 2003)
Early v. R & J Technical Services, Inc.
129 So. 3d 46 (Louisiana Court of Appeal, 2013)
Holt v. Ace American Insurance Co.
149 So. 3d 886 (Louisiana Court of Appeal, 2014)
Speyrer v. Gray Insurance Co.
83 So. 3d 1231 (Louisiana Court of Appeal, 2012)
Day v. Allen
129 So. 260 (Louisiana Court of Appeal, 1930)

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Tony Barnes v. Reata L. West, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tony-barnes-v-reata-l-west-lactapp-2015.