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Kendrick v. Hercules Concrete Pumping Service of Mississippi, Inc.

Citations: 216 So. 3d 261; 2017 WL 655907; 2017 La. App. LEXIS 233Docket: No. 51,190-CA

Court: Louisiana Court of Appeal; February 16, 2017; Louisiana; State Appellate Court

Narrative Opinion Summary

The case involves Hurchel Kendrick's appeal against the summary judgment dismissing his wrongful termination claim against his employer, Hercules Concrete Pumping Services of Mississippi, Inc. Kendrick, a concrete pump truck operator, sustained a work-related injury and later settled his workers' compensation claim. He claimed he was wrongfully terminated after a subsequent incident, asserting that his discharge was retaliatory for pursuing workers' compensation. The key legal issue revolves around La. R.S. 23:1361, which prohibits employee termination for filing such claims. The trial court granted Hercules's summary judgment motion based on a release Kendrick signed, allegedly resigning his position, but Kendrick argued there was no resignation discussion during the settlement. The appellate court found genuine issues of material fact regarding the true motive behind Kendrick's termination, particularly given contradictory statements from his supervisor and the timing related to his workers' compensation claims. Consequently, the summary judgment was reversed, and the case remanded for further proceedings, while Hercules's request for damages on grounds of a frivolous appeal was denied.

Legal Issues Addressed

Frivolous Appeals

Application: Hercules' request for damages for a frivolous appeal is denied due to the presence of genuine factual disputes over Kendrick's termination.

Reasoning: Consequently, Hercules's request for damages for a frivolous appeal is denied.

Release of Employment Claims

Application: The validity of the release signed by Kendrick, which included a resignation from employment and waiver of claims, is scrutinized in determining the wrongful termination claim.

Reasoning: The document titled "RELEASE" includes a paragraph in which Hurschel Kendrick voluntarily resigns from HERCULES CONCRETE PUMPING SERVICES OF MS, INC. and releases the company from all liabilities related to his employment.

Summary Judgment Standards

Application: The appellate court reviews the granting of summary judgment de novo, focusing on whether there are genuine issues of material fact regarding Kendrick's termination.

Reasoning: Summary judgment is reviewed de novo when there is no genuine issue of material fact.

Wrongful Termination under La. R.S. 23:1361

Application: The court examines whether Kendrick's discharge was due to his assertion of a workers' compensation claim, constituting wrongful termination under Louisiana law.

Reasoning: Kendrick filed a tort action against Hercules, alleging wrongful dismissal for exercising his right to workers' compensation, citing La. R.S. 23:1361, et seq.