Todd Suprun VS Louisiana Farm Bureau Mutual Insurance Company, Stan Williams As Administrator of th Estate of His Minor Child, Chad Williams, Chad M. Williams and Government Employees Insurance Company (GEICO)

Annotate this Case
Download PDF
STATE OF LOUISIANA COURT OF APPEAL FIRST CIRCUIT 2009 CA 1555 TODD SUPRUN In fjf VERSUS LOUISIANA FARM BUREAU MUTUAL INSURANCE COMPANY ET AL On Appeal from the 19th Judicial District Court Parish of East Baton Rouge Louisiana Docket No 512 Section 26 114 Honorable Kay Bates Judge Presiding Ralph L Fletcher Fletcher Roy L C Baton Rouge LA Attorney for Plaintiff Appellee Stacey Moak Christopher A Mason Baton Rouge LA Attorneys for Appellants Defendants Todd Suprun Louisiana Farm Bureau Casualty Insurance Co and Chad Williams BEFORE PARRO KUHN AND MCDONALD JJ Judgment rendered APR 3 0 2010 PARRO J The defendants appeal two related judgments that involve motions to tax costs and to set judicial interest as well as the legal effect of an offer of judgment made by the defendants For the following reasons one judgment is set aside in part and the other judgment is affirmed Factual Background and Procedural History On December 7 2002 Todd Suprun Suprun was stopped at a red traffic signal in his pickup truck when he was hit from behind by a vehicle driven by Chad Williams Williams At the scene of the accident Suprun denied being injured however he began experiencing headaches and neck pain shortly after for which he began receiving treatment from a chiropractor on January 8 2003 Suprun filed suit against Williams Williams insurer Louisiana Farm Bureau Casualty Insurance Company Farm Bureau and others to recover for his injuries On October 30 2006 prior to a jury trial on the merits Farm Bureau and Williams collectively referred to as Farm Bureau submitted an offer of judgment for 22 which was rejected by Suprun 90 465 r399 After a trial the jury awarded 16 in favor of Suprun against 40 171 Farm Bureau From the resulting judgment dated February 1 2007 Suprun appealed to this court Although Suprun had back surgery to remove an extruded disc fragment and incurred over 30 in medical expenses the 000 jury awarded only 10 for the medical expenses It also awarded 800 40 371 for past lost wages and 5 for past and future physical pain and suffering 000 while declining to make an award for past and future mental anguish or loss of enjoyment of life On appeal Suprun assigned error to the monetary awards 1 Suprun motion for a judgment notwithstanding the verdict or in the alternative a new trial s was denied The resulting judgment revealed that court costs would be determined at a separate hearing K urging that the record supported a much greater award in all categories Notably the February 1 2007 judgment also ordered Farm Bureau to pay interest from the date of judicial demand until October 30 2006 which amounted to 3 This portion of the judgment was not challenged by 62 090 Suprun on appeal After a thorough review of the record this court concluded that there was a rational basis for the jury decision to award less than the full amounts s claimed by Suprun Accordingly the judgment was affirmed See Suprun v Louisiana Farm Bureau Mutual Insurance Company 080241 La App 1st Cir 08 12 9 unpublished opinion Suprun did not apply for a rehearing with this court or a writ of certiorari with the supreme court Therefore the February 1 2007 judgment became final and definitive See LSAC art 2166 P C A Subsequently in connection with the offer of judgment that was made prior to trial Farm Bureau filed a Rule to Tax Costs and Motion to Set Final Judgment r389 In its filing Farm Bureau asserted a claim for postoffer costs in the amount of 13 11 in costs plus 1 in 20 69 827 857 51 969 judicial interest pursuant to LSAC art 970 leaving an alleged P C C judgment balance of 5payable to Suprun 82 434 Suprun responded by filing a Motion and Order to Tax Court Costs and Judicial Interest from Date of Judicial Demand until the Judgment is Paid Against Chad Williams and Louisiana Farm Bureau Casualty Insurance Company r449 Then Farm Bureau filed a Petition for Concursus relative to the contested portion 13 of the trial court judgment pending a 20 827 determination of the amount due to Suprun after adjudication of its rule r451 The trial court denied the petition for concursus based on the fact that Z Suprun also assigned error to an evidentiary ruling by the trial court which was found by this court to lack merit 3 The sum of 16 damage award plus 3 judicial interest from the date of 40 171 62 090 judicial demand through October 30 2006 equals 19 total award The total award 02 262 of 19 less 13 claim for costs equals 5 balance owed on total 02 262 20 827 82 434 award Notably a check was tendered by Farm Bureau to counsel for Suprun in December r458 2008 3 the total amount due was unknown at that time r457 Pursuant to these motions the trial court by judgment dated March 5 2009 awarded 4 in court costs and expert witness fees to Suprun 66 098 ordered that its February 1 2007 judgment be amended to order payment of judicial interest from the date of judicial demand until the February 1 200 7 Judgment is paid and denied Farm Bureau rule to tax costs and its request s for enforcement of the offer of judgment r475 In a motion for new trial Suprun sought to have the March 5 2009 judgment amended to accurately reflect court costs and expert fees as follows r478 Awarded Actual Court Costs 19 JDC 30 252 1 Expert fee Dr Martello 00 500 1 30 327 1 00 500 1 00 900 00 900 Videographer Dr Johnston deposition 00 150 00 455 Baton Rouge Court Reporter Dr Johntson deposition 36 296 35 296 66 098 4 65 478 4 Expert fee Dr F Allen Johnston In his motion for new trial Suprun also sought to have the trial court declare that Farm Bureau offer s of judgment did not meet the strict service requirements of LSA C arts 970 and 1313 and that Farm Bureau had P A B failed to prove that Suprun acted unreasonably in rejecting the offer of judgment r480 A motion for new trial regarding the March 5 2009 judgment was also filed by Farm Bureau which sought reversal of the trial s court ruling on the motions r487 The trial court denied Farm Bureau motion for a new trial but granted s s Suprun motion In a judgment dated May 12 2009 the court amended its award of costs and expert fees as requested by Suprun and also provided for the recovery of 285 in medical records costs 35 r491 Thus the award of costs and fees was increased from 4 to 4 66 098 764 Notably the judgment dated May 12 2009 did not address the issues raised by Suprun relating to the offer of judgment 4 4 actual costs listed 65 478 however the trial court in oral reasons 35 285 medical records costs 4 764 4 stated that Farm Bureau offer of judgment failed as a matter of law since it s did not comply with the service requirements outlined in LSAC arts P C A 970 and 1313 The trial court observed that Farm Bureau failed to offer B a certificate of the manner in which service was made r521 Farm Bureau appealed the March 5 2009 judgment and the May 12 2009 judgment Offer of Judgment On October 30 2006 Farm Bureau sent a facsimile to Suprun counsel s which in pertinent part provided 699 For the reasons above Farm Bureau makes this offer of judgment pursuant to La C Article 970 without any CR admission of liability In the spirit of compromise Farm Bureau is willing to offer 90 465 22 inclusive of all medical bills ledger court costs and any other amounts except judicial interest which may be awarded pursuant to statute or rule in full settlement of Mr Todd sclaims for damages against Farm Bureau and its insured Suprun in the above referenced suit This offer of judgment includes all claims made against Farm Bureau and its insured in the above referenced suit including but not limited to claims made pursuant to La R 22 and or 22 S 658 1220 Please respond to this offer of judgment within ten 10 days of receipt of the same If the offer is not accepted within the above time it will be deemed withdrawn Emphasis added Concerning an offer of judgment LSAC art 970 P C provides A At any time more than thirty days before the time specified for the trial of the matter without any admission of liability any party may serve upon an adverse party an offer of judgment for the purpose of settling all of the claims between them The offer of judgment shall be in writing and state that it is made under this Article specify the total amount of money of the settlement offer and specify whether that amount is inclusive or exclusive of costs interest attorney fees and any other amount which may be awarded pursuant to statute or rule Unless accepted an offer of judgment shall remain confidential between the offeror and offeree If the adverse party within ten days after service serves written notice that the offer is accepted either party may move for judgment on the offer The court shall grant such judgment on the motion of either party B An offer of judgment not accepted shall be deemed withdrawn and evidence of an offer of judgment shall not be admissible except in a proceeding to determine costs pursuant to 5 this Article C If the final judgment obtained by the plaintiff offeree is at least twenty percent less than the amount of the offer of five judgment made by the defendant offeror or if the final judgment obtained against the defendant offeree is at least twenty five percent greater than the amount of the offer of judgment made by the plaintiff offeror the offeree must pay the offeror costs s exclusive of attorney fees incurred after the offer was made as fixed by the court D The fact that an offer is made but not accepted does not preclude a subsequent offer or a counter offer When the liability of one party to another has been determined by verdict order or judgment but the amount or extent of the damages remains to be determined by future proceedings either party may make an offer of judgment which shall have the same effect as an offer made before trial if it is served within a reasonable time not less than thirty days before the start of hearings to determine the amount or extent of damages E For purposes of comparing the amount of money offered in the offer of judgment to the final judgment obtained which judgment shall take into account any additur or remittitur the final judgment obtained shall not include any amounts attributable to costs interest or attorney fees or to any other amount which may be awarded pursuant to statute or rule unless such amount was expressly included in the offer F A judgment granted on a motion for judgment on an offer of judgment is a final judgment when signed by the judge however an appeal cannot be taken by a party who has consented to the judgment Under the facts of this case Article 970 essentially provides that postoffer costs shall be awarded to a defendant offeror whose pretrial offer is rejected and the final judgment obtained by the plaintiff offeree is at least 25 percent less than the offer See LSA C art 970 Article 970 is punitive in nature P C and its function is to compensate the rejected offeror who is forced to incur greater trial litigation costs that could have been avoided if the offeree had not acted unreasonably in rejecting the offer Held v Aubert 021486 La App 1st Cir 5 845 So 625 636 Statutes that authorize the imposition of 03 9 2d a penalty are to be strictly construed Id see Crawford v United Service Auto Ass 032117 La App 1st Cir 3899 So 668 671 n 05 24 2d Based on the terms of Article 970 Farm Bureau contends that Suprun s C recovery should be limited and that it is entitled to recover postoffer costs pursuant to paragraph C After performing the math the trial court disagreed The February 1 2007 judgment provided for the following awards in favor of Suprun 40 371 10 00 800 00 000 5 40 171 16 past medical expenses past lost wages past and future physical pain and suffering total damage award exclusive of costs The amount offered by Farm Bureau was 22 Seventy percent of 90 465 five that amount is 16 which is exactly 25 percent less than the amount of 43 849 the offer Thus Farm Bureau contends the total damage award of 16 40 171 was at least 25 percent less than the amount of the offer and was less than 25 percent by 678 Accordingly Farm Bureau urges that it is entitled to costs 03 under LSAC art 970 Based on the language of its offer of judgment P C C we disagree Louisiana Code of Civil Procedure article 970 provides E For purposes of comparing the amount of money offered in the offer of judgment to the final judgment obtained which judgment shall take into account any additur or remittitur the final judgment obtained shall not include any amounts attributable to costs interest or attorney fees or to any other amount which may be awarded pursuant to statute or rule unless such amount was expressly included in the offer Emphasis added The offer of judgment in this matter clearly states that the amount of the 90 465 22 offer included damages as well as medical bills ledger court costs and any other amounts except judicial interest which may be awarded pursuant to statute or rule So in evaluating the applicability of LSAC art P C C 970 we are not confined to the monetary awards made in the February 1 2007 judgment Although the amount of medical expenses lost wages and general damages to which Suprun was entitled was set in the February 1 2007 judgment the amount of costs to which he was entitled was not fixed at s 16 16 43 40 849 171 03 678 Mathematically this means the final judgment obtained by the plaintiff offeree was 28 percent less than the amount of the offer of judgment 02 7 that time Notably that judgment specifically provided that COURT COSTS WOULD BE DETERMINED AT A SEPARATE HEARING r332 As the prevailing party in his personal injury action against Farm Bureau pursuant to the February 1 2007 judgment Suprun was entitled to recover costs See LSAC art 1920 P C And according to the offer of judgment Suprun was entitled to have the trial court subsequent award of ledger court s costs and any other amounts except judicial interest which may be awarded pursuant to statute or rule added to the total damage award made in the February 1 2007 judgment for purposes of determining if Suprun recovery s exceeded 75 percent of the amount of the offer Suprun properly moved to have those costs fixed by filing a rule to show cause See LSAC art 1920 P C LSAR 13 and C S 3666 2 B Under LSAR 13 and 13 as well as LSAC art 1920 S 3666 4533 P C the trial court has great discretion in awarding costs including expert witness fees deposition costs exhibit costs and related expenses Samuel v Baton Rouge General Medical Center 991148 La App 1st Cir 10 798 So 00 2 2d 126 131 32 citing Bourgeois v Heritage Manor of Houma 96 0135 La App 1st Cir 2 691 So 703 706 97 14 2d The trial court by judgment dated March 5 2009 awarded 4 in costs to Suprun However this amount 66 098 was increased to 4 by judgment dated May 12 2009 pursuant to a 764 motion for new trial The final award of costs included 6 In accordance with LSAC art 970 in order for a plaintiffofferee to defeat a P C C defendantofferor entitlement to costs the final judgment obtained by the plaintiff offeree s must be greater than the amount of the offer after deducting from the offer a sum equal to 25 percent of that offer In other words the final judgment obtained by the plaintiff offeree must exceed the amount that is 75 percent of the offer LSAR 13 defines costs as the costs of the clerk sheriff witness fees costs of S 4533 taking depositions and copies of acts used on the trial and all other costs allowed by the court 8 Court Costs 19th JDC 30 327 1 Expert fee Dr Ned Martello 00 500 1 00 900 Expert fee Dr F Allen Johnston 00 455 Videographer Dr Johnston deposition 35 296 Baton Rouge Court Reporter Dr Johnston deposition Medical Records Costs 35 285 00 764 4 Farm Bureau offer of judgment only excluded the amount of judicial interest s from consideration for purposes of determining the applicability of LSAC P C art 970 to the facts of this case C Therefore we find no error in the trial s court consideration of the amount of costs awarded pursuant to Suprun s motion to tax costs in determining Farm Bureau claim for postoffer costs s under LSAC art 970 as those amounts may be awarded pursuant to P C C statute or rule See LSAC art 970 P C E Farm Bureau urges that consideration of the cost awards should have been limited to those clerk costs reasonably incurred and on the clerk s s ledger prior to the offer of judgment This overlooks the fact that the offer of judgment authorized the consideration of any other amounts except judicial interest which may be awarded pursuant to statute or rule in addition to ledger court costs and that the offer of judgment did not expressly limit such consideration to those costs Suprun incurred through the date the offer of judgment was made iOctober 30 2006 The final judgment obtained by e Suprun including damages and costs was for 20 which obviously 40 935 exceeded 16 the amount that is 75 percent of the offer of judgment 43 849 Accordingly we conclude that the failure to award Farm Bureau postoffer costs under LSAC art 970 was correct since the final judgment obtained by P C C Suprun inclusive of costs was more than 75 percent of Farm Bureau offer 8 s Judicial Interest With respect to the February 1 2007 judgment award of judicial s 8 Furthermore we pretermit discussion of Suprun argument that Farm Bureau s s noncompliance with the service requirements of LSAC arts 970 and 1313 precluded P C A B an award of postoffer costs to Farm Bureau under LSAC art 970 P C C 9 interest the trial court remarked that it was not sure why language limiting the accrual of interest to October 30 2006 had been included in the judgment 616 Citing LSA C art 1921 which provides for an award of interest as P prayed for or as provided by law the trial court observed that it should never have signed a judgment containing such limiting language Accordingly in connection with Suprun motion to tax costs the March 5 2009 judgment s amended the February 1 2007 judgment to award judicial interest from the date of judicial demand until paid Relying on Palmer v Leclerco 070604 La App 4th Cir 9 996 08 24 2d So 21 writ denied 08 2532 La 1 998 So 102 the trial court 09 16 2d found that the change of phraseology relative to the award of judicial interest was not substantive even though it would result in the payment of more interest since Suprun was entitled by operation of law to interest until the date of payment Concerning the nature of the amendment the trial court stated r517 It was legally incorrect for the judgment to say that the interest would cease to accrue on October 30th of 2006 By amending the language of the judgment I am simply bringing it in line with the underlying statutory law and jurisprudence Since the court lacks the authority to deny the plaintiff interest in the first place I hardly think that the amendment effects a substantive change in the judgment under LSA C art 1951 P Farm Bureau disagreed urging that the amendment constituted a substantive change and that the trial court was without authority to modify the award of judicial interest that had been made in the February 1 2007 judgment A judgment is the determination of the rights of the parties in an action and may award any relief to which the parties are entitled interlocutory or final It may be LSAC art 1841 A judgment that determines the P C merits in whole or in part is a final judgment Id A final judgment may be 9 See LSA R 13 legal interest shall attach from date of judicial demand on all S 4203 judgments sounding in damages ex delicto which may be rendered by any of the courts A court lacks discretion to deny interest if interest is prayed for or provided for by law Bickham v Bickham 021307 La App 1st Cir 5 849 So 707 71011 9103 2d 10 amended by the trial court at any time with or without notice on its own motion or on motion of any party to alter the phraseology of the judgment but not the substance or to correct errors of calculation LSAC art 1951 P C In other words a judgment may be amended by the court where the resulting judgment takes nothing from or adds nothing to the original judgment Villaume v Villaume 363 So 448 450 La 1978 However an 2d amendment to a judgment which adds to subtracts from or in any way affects the substance of the judgment is considered a substantive amendment Starnes v Asolundh Tree Expert Company 941647 La App 1st Cir 10 95 6 670 So 1242 1246 Substantive amendments to judgments can be made 2d only after a party has successfully litigated a timely application for new trial an action for nullity or a timely appeal Creel v Bogalusa Community Medical Center 580 So 551 552 La App 1st Cir writ denied 585 So 567 La 2d 2d 1991 In Villaume the Louisiana Supreme Court recognized that substantive amendments can also be made on the trial court own motion with the s consent of the parties Frisard v Autin 982637 La App 1st Cir 12 99 28 747 So 813 818 writ denied 00 0126 La 3 756 So 1145 2d 00 17 2d The judgment rendered after the trial of this matter provided for interest from the date of judicial demand until October 30 2006 judgment was affirmed by this court and became final That See Su run 080241 unpublished opinion LSA C art 2166 Thus Farm Bureau argues that a P subsequent amendment of that judgment to order payment of judicial interest from the date of judicial demand until paid was in error The trial court amendment increased the amount of legal interest that s Suprun was entitled to recover from Farm Bureau An amendment to a final judgment to add interest is a substantive change which is not permitted under LSAC art 1951 despite the fact that an award of legal interest in tort P C cases is not discretionary with the court since interest attaches automatically 11 until judgment is paid See LSA C art 1921 LSA R 13 O P S 4203 Brien v Hoff 08520 La App 5th Cir 3 10 So 802 805 Odom v City of 09 24 3d Lake Charles 001050 La App 3rd Cir 1 790 So 51 63 writ 01 31 2d denied 01 1198 La 6 794 So 787 01 22 2d see also Mack v Wile v 07 2344 La App 1st Cir 5 991 So 479 486 writ denied 081181 La 08 2 2d 08 19 9 992 So 932 holding that an amendment of a final judgment to 2d assess costs is an impermissible substantive change Oreman v Oreman 05 955 La App 5th Cir 3 926 So 709 712 writ denied 06 1130 La 06 31 2d 06 1 9 936 So 206 2d Louisiana Power Light Co v Parish School Bd of Parish of St Charles 93 249 La App 5th Cir 2 639 So 760 763 94 11 2d writ denied 94 604 La 4 640 So 1317 finding that an award of 94 22 2d legal interest would result in a substantive amendment of a final judgment contrary to law It is clear from a reading of the two judgments in this case that the March 5 2009 judgment contains a substantive change in the assessment of judicial interest This substantive alteration is in violation of the prohibition contained in LSAC art 1951 P C A judgment that has been signed cannot be altered amended or revised by the judge who rendered the same except in the manner provided by law Bourgeois v Kost 02 2785 La 5 846 So 692 696 The trial judge 03 20 2d cannot on his own motion or on the motion of any party change a judgment which has been so signed notwithstanding it was signed in error Id Without a specific statutory grant of authority the trial court is limited to the general authorization for amending final judgments provided in LSAC art 1951 P C As stated above this Article limits the amendment of judgments to the correction of errors in calculation and alteration of phraseology It does not authorize a trial court to make substantive amendments to final judgments Substantive amendments to judgments made without recourse to the proper procedures i by way of a timely motion for a new trial or by appeal are e 12 absolute nullities See Bourgeois 846 So at 696 2d Therefore that portion of the March 5 2009 judgment amending the award of judicial interest is a nullity even though it was to correct a legal error since it amounted to more than a mere alteration of the phraseology of the February 1 2007 judgment See Melancon v Insurance Corp of America 633 2d So 231 23233 La App 1st Cir 1993 O 10 So at 805 cf Brien 3d Palmer 996 So 21 2d In connection with his motion to tax costs and to set judicial interest from the date of judicial demand until payment Suprun urged that the trial court had legally erred in the assessment of costs in the original judgment Assuming for the sake of argument that Suprun pleading in part could be s construed as a petition to annul 12 that portion of the February 1 2007 judgment awarding judicial interest we observe that the action to annul provided by LSAC art 2004 is not a substitute for an appeal from a P C judgment that might be erroneous due to misinterpretation of substantive law io In Melancon a medical malpractice case this court found that the plaintiffs failure to raise the issue of interest on appeal precluded the trial court from amending the date from which interest was to begin to accrue See Melancon 633 So at 232 33 2d 11 The court in Palmer disagreed with this court opinion in Melancon finding that such an s amendment did not alter the substance of the prior judgment Palmer 996 So at 26 n 2d 2 The plaintiffs in Palmer requested interest from the date of filing of the complaint in medical malpractice or alternatively the date of judicial demand The original judgment provided for interest from the date of judicial demand The second judgment provided that interest on the damages would accrue from the date of the filing of the complaint with the board The court found that the amendment merely altered the phraseology of the prior judgment to clarify that the plaintiffs were entitled by operation of law to interest from the date of the filing of the complaint with the board for a medical review panel Palmer 996 So at 2526 2d 12 The nullity of a final judgment may be demanded for vices of either form or substance as provided in LSAC arts 2002 through 2006 LSAC art 2001 A final judgment shall P C P C be annulled if it is rendered 1 Against an incompetent person not represented as required by law 2 Against a defendant who has not been served with process as required by law and who has not waived objection to jurisdiction or against whom a valid judgment by default has not been taken 3 By a court which does not have jurisdiction over the subject matter of the suit LSAC art 2002 Furthermore a final judgment obtained by fraud or ill practices may P C A be annulled LSAC art 2004 P C A 13 but is a separate remedy designed to afford relief against a judgment procured by methods viewed with disdain by the judiciary See Smith v Cajun Insulation Inc 392 So 398 401 La 1980 Errors of law cannot serve as 2d grounds for an action of nullity See Fidelity and Casualty Co of New York v Clemmons 198 So 695 698 La App 1st Cir writ denied 251 La 27 202 2d 2d So 649 1967 Judgments are not infallible However even if an error is made once a judgment becomes final it is not reversible on grounds of mere error Livingston Parish Sewer Dist No 2 v Millers Mut Fire Ins Co of Texas 99 1728 La App 1st Cir 9 767 So 949 953 writ denied 002887 00 22 2d La 12 776 So 1175 00 8 2d The usual remedy applied by an appellate court when it finds an amendment of substance has been made in a judgment is to annul and set aside the amending judgment and reinstate the original judgment See McGee v Wilkinson 031178 La App 1st Cir 4 878 So 552 554 Magill v 04 2 2d State Dept of Public Safety and Corrections 27 La App 2nd Cir 802 96 24 1 666 So 1260 1263 Alliance for Good Government Inc v 2d Jefferson Alliance for Good Government Inc 96 309 La App 5th Cir 96 16 10 683 So 836 839 2d Decree For the foregoing reasons we annul and set aside that portion of the March 5 2009 judgment that 076 ORDERED ADJUDGED AND DECREED that the Judgment signed February 1 200 is hereby amended to correctly show 7 that judicial interest on the Judgment is due from the date of judicial demand until the February 1 200 Judgment is paid 7 instead of limiting judicial interest until October 30 2006 thereby GRANTING Todd Suprun Motion to assess judicial interest from s date of judicial demand until paid In addition to this action we reinstate in effect the award of legal interest on 13 the 16 damage award made in the February 1 2007 judgment 40 171 13 In so ruling we render no opinion as to the correctness of the trial court initial decision to s terminate the award of judicial interest as of the date the offer of judgment was made 14 Otherwise we affirm the March 5 2009 judgment of the trial court as amended by the May 12 2009 judgment with respect to the taxing of costs We also affirm the May 12 2009 judgment Costs of this appeal are assessed to Chad Williams and Louisiana Farm Bureau Casualty Insurance Company MARCH 5 2009 JUDGMENT SET ASIDE IN PART AND AFFIRMED IN PART MAY 12 2009 JUDGMENT AFFIRMED 15

Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.