Winnie Lott v. Ace American Ins. Co.

CourtLouisiana Court of Appeal
DecidedFebruary 26, 2025
DocketCA-0024-0470
StatusUnknown

This text of Winnie Lott v. Ace American Ins. Co. (Winnie Lott v. Ace American Ins. Co.) 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
Winnie Lott v. Ace American Ins. Co., (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

24-469

consolidated with 24-470, 24-471, 24-472, 24-473, 24-474, 24-475, 24-476, 24-477

MARTHA BROWN

VERSUS

ARKITA JOHNSON, ET AL

**********

APPEAL FROM THE NINTH JUDICIAL DISTRICT COURT PARISH OF RAPIDES, NO. 267,149 consolidated with Nos. 269,028; 267,265; 269,040; 269,048; 269,089; 269,293; 269,306; and 269,479 HONORABLE MONIQUE FREEMAN RAULS, DISTRICT JUDGE

********** CLAYTON DAVIS JUDGE **********

Court composed of Jonathan W. Perry, Sharon Darville Wilson, and Clayton Davis, Judges.

AFFIRMED. Donald Ray Brown Attorney at Law P. O. Box 12478 Alexandria, Louisiana 71315-2478 Telephone (318) 487-9976 COUNSEL FOR THIRD PARTY/APPELLEE: Winnie Lott

Julius Willis Grubbs, Jr. Haik, Minvielle & Grubbs 1101 E. Admiral Doyle Drive #503 New Iberia, Louisiana 70560 Telephone (337) 365-5486 COUNSEL FOR THIRD PARTY/APPELLEE: Christus St. Francis Cabrini Hospital

Edward S. Johnson Attorney at Law 701 Poydras Street, Suite 4700 New Orleans, Louisiana 70139-7701 Telephone (504) 528-3001 COUNSEL FOR DEFENDANT/APPELLANT: Ace American Ins. Co. Arkita Johnson Martin Marietta Materials, Inc.

Thomas Benjamin Moyse Wahlder Attorney at Law 1740 Jackson Street Alexandria, Louisiana 71306 Telephone (318) 442-9417 COUNSEL FOR PLAINTIFF/APPELLEE: Martha Brown

Joseph B. Stamey Stamey Law Firm, LLC PO Drawer 1288 Natchitoches, Louisiana 71458-1288 Telephone (318) 352-4559 COUNSEL FOR DEFENDANT/APPELLANT: Ace American Ins. Co. Arkita Johnson Martin Marietta Materials, Inc. Laurie Ann Simms Thomas B. Wahlder Firm 1740 Jackson Street Alexandria, Louisiana 71306 Telephone (318) 442-9417 COUNSEL FOR PLAINTIFF/APPELLEE: Martha Brown

Paul J. Tellarico Brian Caubarreaux & Associates 2204 McArthur Drive Alexandria, Louisiana 71301 Telephone (318) 442-0900 COUNSEL FOR THIRD PARTY/APPELLEE: James Ayres Debra Swearington Sheterrian Sewell Derrick Wilson

Lewis Olivier Lauve, Jr. Bussey & Lauve, LLC P. O. Drawer 8778 Alexandria, Louisiana 71306 Telephone (318) 449-1937 COUNSEL FOR THIRD PARTY/APPELLEE: City of Alexandria

Byron O’Neal O’Neal Law Firm 1847 Sterkx Road Alexandria, Louisiana 71301 Telephone (318) 487-8787 COUNSEL FOR THIRD PARTY/APPELLEE: Marrison Wright James Odom Charles Price Shirley Cooper Odom Vickie L. Odom Bronnie Odom Shirley Cooper Odom obo Jerry Cooper, deceased

Shawn M. Bordelon Laborde Earles Law Firm 100 Versailles Blvd., Suite A Alexandria, Louisiana 71303 Telephone (318) 373-6321 COUNSEL FOR THIRD PARTY/APPELLEE: Derrick Vales Joshua J. Dara, Jr. Gold, Weems, Bruser P. O. Box 6118 Alexandria, Louisiana 71301 Telephone (318) 445-6471 COUNSEL FOR THIRD PARTY/APPELLEE: City of Alexandria

Stephen J. Hecker Attorney at Law 631 St Charles Ave, Suite 2F New Orleans, Louisiana 70130 Telephone (504) 446-1000 COUNSEL FOR PLAINTIFF/APPELLEE: Martha Brown

Rachel Coronel Gordon McKernan 4207 Parliament Drive, Suite A Alexandria, Louisiana 71303 Telephone (318) 443-8888 COUNSEL FOR THIRD PARTY/APPELLEE: Connie Combs Hope Carter Darryl Williams DAVIS, Judge.

These consolidated actions arise from an automobile accident in December

2019 in Alexandria. Martha Brown, a City of Alexandria employee, was driving a

city bus with several passengers on board when she proceeded through an

intersection on a green light. Arkita Johnson, an employee of Martin Marietta

Materials, Inc., was operating a company pickup truck. The pickup entered the

intersection first, despite being faced with a red light, and the front of the bus collided

with the pickup’s front driver side. The bus proceeded through the intersection and

drifted off the roadway. Brown fell out of the driver’s seat as the bus jumped a curb

and struck a brick wall and then a utility pole.

Brown and other injured plaintiffs, along with the City of Alexandria, sued

Johnson, Martin Marietta, and Ace American Insurance, alleging the negligence of

Johnson and Martin Marietta.1 Some of the plaintiffs also named Brown and the

City as defendants, alleging their negligence. Various third party demands and

interventions were also filed, all centered around the negligence of Johnson and/or

Brown.

The trial court bifurcated trials on the issues of liability and damages. The

City’s liability was tried to the judge, while a jury determined the liability of the

other defendants. The trial court and the jury both found Arkita Johnson 100% at

fault.

Martin Marietta appeals the judgment alleging the trial court: 1) erroneously

granted Brown’s motion to strike Johnson’s expert witnesses, and 2) instructed the

jury with confusing and inconsistent statements of the law. Martin Marietta also

appeals the assignment of all fault against Johnson and the failure to attribute any

1 We refer to Johnson, Martin Marietta, and Ace collectively as “Martin Marietta” in this opinion. fault to Brown because of her breach of the heightened standard of care applicable

to a professional driver.

For the reasons discussed below, we affirm in all respects the judgment from

the trial court.

Motion to Strike Martin Marietta’s Expert Witnesses

Counsel for Brown and the City sent discovery requests to Martin Marietta in

February 2020 asking it to identify witnesses, particularly expert witnesses, they

intended to call at trial. Price’s counsel propounded a similar request in September

2020.

Martin Marietta’s counsel objected to the discovery requests as premature and

said experts would be listed in accordance with the court’s scheduling order. They

never supplemented the response. In October 2020, accident reconstructionist

Jeremy Hoffpauir and biomedical engineer Jeffrey Wheeler attended an inspection

of the bus involved in the accident. On August 30, 2023, Martin Marietta identified

Mr. Hoffpauir and Mr. Wheeler as witnesses to be called at trial. This disclosure was

ninety days before trial and sixty days before the discovery deadline, in accordance

with the court’s scheduling order and deadline to disclose experts.

Brown filed a motion to exclude the testimony of Mr. Hoffpauir and Mr.

Wheeler at trial because Martin Marietta had not identified them in discovery. The

trial court granted the motion. Although Martin Marietta indicated it would seek a

supervisory writ at the hearing, it never did. Martin Marietta made no proffer of the

experts’ testimony either at the hearing or at trial.

Louisiana Code of Civil Procedure Article 1636 allows a party to offer

excluded evidence and subject it to cross-examination. When such a proffer is made,

the trial court shall state its reasons for excluding the evidence on the record. That

decision is reviewable on appeal. The failure to proffer excluded testimony does not

2 prohibit appellate review when the record on appeal clearly shows the content of the

excluded testimony. Williams v. Lafayette City-Par. Consol. Gov’t, 11-281 (La.App.

3 Cir. 10/5/11), 72 So.3d 1023, writ denied, 11-2473 (La. 2/3/12), 79 So.3d 1027.

The Williams plaintiff sustained injury when she fell on a public bus. She

offered testimony of a witness about the bus operator’s driving habits and the

defendant’s training procedures. The trial court excluded the testimony as irrelevant,

and the plaintiff’s counsel did not proffer it to the court. Counsel did, however,

inform the court of the topics about which the witness would have testified. On

appeal, this court noted the difference between topics and substance of testimony

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Related

Libersat v. J & K TRUCKING, INC.
772 So. 2d 173 (Louisiana Court of Appeal, 2000)
Smiciklas v. Groendyke Transport, Inc.
505 So. 2d 775 (Louisiana Court of Appeal, 1987)
Williams v. Lafayette City-Parish Consolidated Government
72 So. 3d 1023 (Louisiana Court of Appeal, 2011)

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