Victoria Dauzat v. Dolgencorp, LLC

CourtLouisiana Court of Appeal
DecidedApril 6, 2016
DocketCA-0015-1096
StatusUnknown

This text of Victoria Dauzat v. Dolgencorp, LLC (Victoria Dauzat v. Dolgencorp, LLC) 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
Victoria Dauzat v. Dolgencorp, LLC, (La. Ct. App. 2016).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL, THIRD CIRCUIT

15-1096

VICTORIA DAUZAT, ET AL.

VERSUS

DOLGENCORP, LLC, ET AL.

************

APPEAL FROM THE TWELFTH JUDICIAL DISTRICT COURT PARISH OF AVOYELLES, DOCKET NO. 2014-1020-A HONORABLE KERRY L. SPRUILL, DISTRICT JUDGE

JAMES T. GENOVESE JUDGE

Court composed of Marc T. Amy, Elizabeth A. Pickett, and James T. Genovese, Judges.

AFFIRMED.

Peter J. Wanek Trevor C. Davies Lou Anne Milliman McCranie, Sistrunk, Anzelmo, Hardy, McDaniel & Welch, LLC 909 Poydras Street, Suite 1000 New Orleans, Louisiana 70112 (504) 831-0946 COUNSEL FOR DEFENDANTS/APPELLANTS: DG Louisiana, LLC and Amanda Poarch Laura Bishop Knoll Jerold Edward Knoll The Knoll Law Firm, LLC Post Office Box 426 Marksville, Louisiana 71351 (318) 253-6200 COUNSEL FOR PLAINTIFFS/APPELLEES: Victoria Dauzat and Phyllis Jeansonne GENOVESE, Judge.

Defendants/Appellants, DG Louisiana, LLC,1 doing business as Dollar

General (hereafter Dollar General), and Amanda Poarch, suspensively appeal an

adverse judgment following a bench trial on Plaintiffs’ claims of defamation and

false imprisonment. The trial court awarded $20,000 in general damages to each

Plaintiff. For the following reasons, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

On April 14, 2014, Plaintiffs, Victoria Dauzat and Phyllis Jeansonne,2

claimed to have been wrongly accused of shoplifting at a Dollar General store

located in Marksville, Louisiana. On October 6, 2014, Plaintiffs filed suit against

Dollar General and Ms. Poarch, the employee who accused Plaintiffs of

shoplifting. Plaintiffs sought damages for defamation and false arrest. Defendants

answered the petition, denying all allegations and asserting immunity for reporting

possible criminal activity.

A bench trial was held on June 24, 2015.3 At the close of Plaintiffs’

case-in-chief, Defendants moved for an involuntary dismissal.4 The trial court took

1 DG Louisiana, LLC, was incorrectly identified as Dolgencorp, LLC. Since the parties refer to this defendant as Dollar General, we will do likewise. 2 Plaintiffs are sisters. 3 Ms. Poarch did not appear at trial. 4 Louisiana Code of Civil Procedure Article 1672(B) governs a motion for involuntary dismissal:

In an action tried by the court without a jury, after the plaintiff has completed the presentation of his evidence, any party, without waiving his right to offer evidence in the event the motion is not granted, may move for a dismissal of the action as to him on the ground that upon the facts and law, the plaintiff has shown no right to relief. The court may then determine the facts and render judgment against the plaintiff and in favor of the moving party or may decline to render any judgment until the close of all the evidence.

We find it noteworthy that after Plaintiffs rested, counsel for Defendants declared, “I just have motions for involuntary dismissal. I can present those, I’m not going to present any evidence[.]” Trial ended after argument relative to the motion for involuntary dismissal. the matter under advisement with post-trial memoranda submitted by the parties.

On August 5, 2015, the trial court rendered lengthy written Reasons for Judgment.5

In that judgment, the trial court denied Defendants’ motion for involuntary

5 The trial court paraphrased the evidence adduced at trial as follows, in pertinent part:

As confirmed by security video footage from the store, both [P]laintiffs entered Dollar General at 11:49 o’clock a.m. and were initially looking at merchandise on a discount rack. Of particular importance is [P]laintiffs’ trial testimonies that confirm the presence of shoppers in the store who[,] among others[,] were church members with [P]laintiff, Victoria Dauzat.

The security camera footage is without question most probative in reconstructing the events at the Dollar General Store and confirms that Amanda Poarch, [D]efendant-[E]mployee for the Dollar General Store commenced observation of surveillance footage in the store’s office at 11:56 o’clock a.m. on the day in question. Her call to police to report an alleged “theft in progress” was made shortly thereafter at 12:04 o’clock p.m. She advised law enforcement in this call that she was presently watching [P]laintiffs steal several items from the store . . . . However, at trial, a review of the security tape does not support a finding of any criminal activity of theft by either Victoria Dauzat or Phyllis Jeansonne. Further, from the surveillance video presented at trial, it is clear that [P]laintiffs were asked to leave the check-out line by law enforcement officers at approximately 12:09 o’clock p.m. The trial evidence further supports a finding that the [P]laintiffs were then and there administered their Miranda rights by law enforcement . . . . The video evidence presented at trial further supports a finding that the questioning of both [P]laintiffs continued in the office at the back of the store and lasted until 12:31 o’clock p.m.[,] at which time the security footage stops without explanation or documentation. Plaintiffs’ testimonies contend that the questioning lasted for an extended period of time and much longer than one (1) hour; [D]efendants failed to produce video footage after 12:31 o’clock p.m. contending that it was not available and did not exist. In this regard, it must not be overlooked that video footage had been requested by [P]laintiffs’ counsel on April 15, 2014, one day after the incident . . . ; the preservation of the video security tapes were vital [to] the determination of legal issues pending before this [c]ourt.

Unique to this case and of concern to this trier of fact is that the detention of [P]laintiffs continued beyond this first round of questioning described above. Both [P]laintiffs were instructed to return to [t]he Dollar General Store for further inquiry into this matter at 3:00 o’clock p.m. on the same day. Plaintiffs’ testimonies reflect that after leaving the Dollar General Store, they went immediately to the home of Phyllis Jeansonne. Their trial testimonies recall the afternoon in question and confirm that neither [Ms.] Dauzat nor [Ms.] Jeansonne felt free and[,] despite their actual innocence, both feared the threat of imminent charges for a crime that they had not committed. Their trial testimonies support a finding that both were justifiably angry and humiliated at having to return to [t]he Dollar General Store. Both [P]laintiffs suffered stress, anxiety, and humiliation, not knowing what would ultimately happen to them relative to the baseless charges of theft. This [c]ourt is further convinced that both [P]laintiffs were humiliated, embarrassed and publicly shamed by the events that occurred. Both were humiliated and concerned that others in their community had received word of the unfounded accusations of theft against them. Their trial testimonies further support a finding that their worst fears had become a reality as the rumors of theft had in fact reached the work place of Phyllis Jeansonne and the church of Victoria Dauzat. Both [P]laintiffs felt that their reputations were damaged. 2 dismissal and found that Defendants had defamed and falsely imprisoned Plaintiffs

and set their general damages at $20,000 each. Judgment was signed August 26,

2015. Defendants have filed a suspensive appeal.

ASSIGNMENTS OF ERROR

Defendants submit the following errors for our review:

1. The trial court erred in finding Dollar General and [Ms.] Poarch liable for defamation, because merchants are entitled to immunity from suit for reporting a suspected crime to police, and there is no evidence that Ms. Poarch’s statements to police were made with malice or reckless indifference as to their truth or falsity.

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Victoria Dauzat v. Dolgencorp, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/victoria-dauzat-v-dolgencorp-llc-lactapp-2016.