Zachary Marcade Versus New York Marine and General Insurance Company and Nola Motor Club, L.L.C.

CourtLouisiana Court of Appeal
DecidedOctober 4, 2023
Docket23-CA-17
StatusUnknown

This text of Zachary Marcade Versus New York Marine and General Insurance Company and Nola Motor Club, L.L.C. (Zachary Marcade Versus New York Marine and General Insurance Company and Nola Motor Club, L.L.C.) 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
Zachary Marcade Versus New York Marine and General Insurance Company and Nola Motor Club, L.L.C., (La. Ct. App. 2023).

Opinion

ZACHARY MARCADE NO. 23-CA-17

VERSUS FIFTH CIRCUIT

NEW YORK MARINE AND GENERAL COURT OF APPEAL INSURANCE COMPANY AND NOLA MOTOR CLUB, L.L.C. STATE OF LOUISIANA

ON APPEAL FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT PARISH OF JEFFERSON, STATE OF LOUISIANA NO. 807-130, DIVISION "J" HONORABLE STEPHEN C. GREFER, JUDGE PRESIDING

October 04, 2023

MARC E. JOHNSON JUDGE

Panel composed of Judges Fredericka Homberg Wicker, Marc E. Johnson, and John J. Molaison, Jr.

REVERSED; REMANDED MEJ FHW JJM COUNSEL FOR PLAINTIFF/APPELLANT, ZACHARY MARCADE Charles M. Thomas Leandro R. Area

COUNSEL FOR DEFENDANT/APPELLEE, NEW YORK MARINE AND GENERAL INSURANCE COMPANY AND NOLA MOTOR CLUB, L.L.C. Mark C. Dodart Stuart G. Richeson James H. Gilbert Harrison M. Martin JOHNSON, J.

Appellant, Zachary1 Marcade, seeks review of the 24th Judicial District

Court’s November 14, 2022 judgment granting the summary judgment filed by

Defendants/Appellees’, New York Marine and General Insurance Company and

NOLA Motor Club, L.L.C.’s (collectively referred to as “NOLA Motor Club”), .

Mr. Marcade sustained serious injuries to his left leg after a collision with a go-kart

operated by his son’s minor friend at NOLA Motor Club’s kart track in Jefferson

Parish. For the following reasons, we reverse the district court’s judgment and

remand the matter.

FACTS AND PROCEDURAL HISTORY

Mr. Marcade and his wife celebrated the birthday of their 12 year old son,

along with two of their son’s minor friends, on August 9, 2019 at a party held at

the NOLA Motorsports Park, operated by NOLA Motor Club, in Avondale, LA.

The party of five participated in the first heat of a race without incident. During the

second heat of the race, Kart #4, driven by one of their minor son’s friends, who is

referred to in the case record as “ST”, spun out in front of Kart #14, the kart Mr.

Marcade was driving. Mr. Marcade’s kart collided into ST’s kart at full speed, and

Mr. Marcade was ejected from Kart #14 upon impact. According to a medical

report completed by the NOLA Motor Club personnel in response to the accident,

a medic placed Mr. Marcade’s deformed left leg in a splint and noted that there

were no other visible injuries. Thereafter, Mr. Marcade was released to the care of

West Jefferson EMS for further treatment.

Before the group began the karting activity, Mr. Marcade’s wife signed a

Parental Consent, Release and Waiver of Liability, Assumption of Risk, and

Indemnity Agreement form, and their son signed a Minor’s Assumption of Risk

1 Here, we use the same spelling of Appellant’s first name as the case caption, although the record suggests it should be spelled “Zacharie”.

23-CA-17 1 and Release and Waiver of Liabilty, before a witness who was an employee of the

track. The group also provided NOLA Motor Sports with forms that had been

signed by ST and his father the day before the party. On the parental consent form,

ST’s father acknowledged:

I know the nature of the EVENT(S) and the Minor’s experience and capabilities, and believe the Minor to be qualified to participate in the Event(s). I will inspect the premises, facilities, and equipment to be used, or with which the Minor may come in contact. IF I OR THE MINOR BELIEVE ANTYTHING IS UNSAFE, I WILL INSTRUCT THE MINOR TO IMMEDIATELY LEAVE THE RESTRICTED AREA AND REFUSE TO PARTICIPATE FURTHER IN THE EVENT(S).

Through signing the forms, the adults also acknowledged the inherent danger and

risk of harm karting poses, and NOLA Motorsports Park’s immunity from liability

pursuant to La. R.S. 9:2795.4.

On June 5, 2020, Mr. Marcade filed a Petition for Damages against NOLA

Motor Club. Mr. Marcade alleged that he “has suffered physical pain and suffering,

mental anguish, medical expenses, permanent disability, and disfigurement among

other damages” as a result of the accident that “was caused solely and proximately

by the negligence of NOLA Motor Club.” NOLA Motor Club filed a Motion for

Summary Judgment on May 5, 2022. In its motion, Appellees alleged that karting

was a “motorized off-road vehicle activity” as contemplated by La. R.S. 9:2795.4,

claimed that they met all of the statute’s requirements, and asserted the immunity

provided by the statute. NOLA Motor Club further argued that Mr. Marcade could

not claim the exception to immunity provided by La. R.S. 9:2795.4(C)(2) because

the statute required activity sponsors to make “reasonable and prudent efforts to

determine the ability of the participant [claiming the exception] to engage safely”

in the activity, and not the other participants partaking in the activity. Mr. Marcade

timely filed an opposition, arguing that the collision was caused by a twelve-year-

old child and NOLA Motor Club violated its own safety policy in allowing a child

23-CA-17 2 under the age of fifteen to operate a SR kart unless the parent confirmed the minor

had prior karting experience; that NOLA Motor Club’s failure to make reasonable

and prudent efforts to determine the participant’s ability to kart safely and their

failure to make sure ST had prior karting experience “constituted willful or wanton

disregard for the safety of the participant” pursuant to La. R.S. 9:2795.4(C)(2) did

in fact apply in this case; NOLA Motor Club had to prove immunity; NOLA Motor

Club’s conduct triggered two of the exceptions to immunity under the statute; and

whether NOLA Motor Club confirmed that ST had prior karting experience was a

genuine issue of material fact in dispute. In the alternative, Mr. Marcade also

argued that La. R.S. 9:2795.4(C)(2) was unconstitutionally vague, and indefinite.

The district court held a hearing on the motion for summary judgment on

October 25, 2022 and granted judgment in favor of NOLA Motor Club at the end

of the hearing. The court found: 1) that NOLA Motor Club met the threshold of

invoking the immunity statute’s protection; 2) the waiver executed by ST’s parent

would satisfy the statute’s requirements such that any exception under Subsection

B would not apply; 3) the father’s certification of ST’s ability to participate in the

activity was the “best discharge” of NOLA Motor Club’s obligation to ensure that

participants could safely engage in karting; 4) that, because ST’s father

acknowledged that he knew that the child was going karting, knew the nature of

karting, and determined that his child could safely participate, it was not NOLA

Motor Club’s responsibility to second guess the parent’s assessment, so (C)(2) did

not apply; 5) the disclosure and waiver executed by ST’s parent made resolution of

the statutory construction question regarding who was a participant under La. R.S.

9:2794.4(C)(2) unnecessary; and 6) verifying that the parent knew about the SR

kart safety policy was good practice, but not necessary to discharge any obligation

that could be found under Subsection (C)(4), again because the parent certified that

the child was capable of participating in the activity. The court also ruled that the

23-CA-17 3 constitutionality of the statute was not properly before the court because the

petition was not served upon the Attorney General.

This timely appeal followed.

ASSIGNMENTS OF ERROR

Appellant assigns the following as error:

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