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Vaughn v. City of Baton Rouge

Citations: 39 So. 3d 799; 2009 La.App. 1 Cir. 0930; 2010 La. App. LEXIS 784; 2010 WL 2109381Docket: No. 2009 CW 0930R

Court: Louisiana Court of Appeal; May 26, 2010; Louisiana; State Appellate Court

Narrative Opinion Summary

In a legal dispute involving the State of Louisiana and the Vaughns, the primary issue revolved around the timeliness of a damage claim related to property flooding. The Vaughns filed their claim more than two years after the alleged harm, prompting the State to assert the one-year liberative prescription period for delictual actions under Louisiana law. However, the Vaughns argued that their intervention in a related lawsuit (the Randolph suit) interrupted this prescriptive period. The court agreed with the Vaughns, noting that their intervention was filed within one year of the flood, effectively notifying the State of their claims and thus interrupting the prescription period. This interruption continued while the related suit was pending and allowed the Vaughns to file their new action within the prescriptive period after their intervention was dismissed without prejudice. The trial court's decision to overrule the State's objection of prescription was affirmed, and the State's writ application to the supreme court was denied. The City-Parish, also named in the claim, did not appeal the trial court's ruling. The court found no evidence of prejudice against the State, emphasizing that under Louisiana law, the interruption of prescription is negated if the plaintiff fails to prosecute the action properly.

Legal Issues Addressed

Burden of Proof for Prescription

Application: Once a claim appears to have prescribed, the burden shifts to the plaintiff to demonstrate that prescription has been suspended or interrupted. The Vaughns successfully demonstrated interruption through their timely intervention.

Reasoning: The court noted that if a claim appears to have prescribed, the burden shifts to the plaintiff to demonstrate that prescription has been suspended or interrupted.

Interruption of Prescription

Application: The court held that the Vaughns' intervention in the Randolph suit interrupted the prescription period, allowing them to file a new action within the prescriptive period after the intervention was dismissed without prejudice.

Reasoning: The Vaughns contended that their intervention in the Randolph suit constituted a valid interruption of prescription, as per Louisiana Civil Code provisions.

Liberative Prescription for Delictual Actions

Application: The State argued that the Vaughns' lawsuit was untimely, citing the one-year liberative prescription period for delictual actions, which begins from the date of injury. However, the court found that the Vaughns' intervention in a related lawsuit interrupted the prescriptive period.

Reasoning: The State argued the lawsuit was untimely, citing the one-year liberative prescription period for delictual actions under Louisiana law, which begins from the date of injury.