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Smith v. Comeaux Furniture & Appliance, Inc.

Citations: 472 So. 2d 210; 1985 La. App. LEXIS 9271Docket: No. CA 3333

Court: Louisiana Court of Appeal; June 18, 1985; Louisiana; State Appellate Court

Narrative Opinion Summary

The case involves a plaintiff who was awarded benefits for a partial disability of his hand under LSA-R.S. 23:1221(4)(e) following an injury sustained while dusting furniture. The plaintiff appealed for penalties and attorney’s fees under R.S. 23:1201.2 and R.S. 22:658, arguing that the defendant’s refusal to pay compensation benefits was arbitrary and capricious. The incident resulted in a diagnosis of 'game keeper's thumb,' with medical reports initially indicating a five percent permanent disability of the thumb. However, this diagnosis was later clarified to refer to a disability of the hand. The defendant contested the claim, citing a lack of confirmation of a hand disability. The court found that the defendant's refusal was indeed arbitrary and capricious, as the operations manager had not questioned the injury when treatment was sought. Consequently, the plaintiff was awarded 12% penalties on the benefits due, amounting to $366, with additional attorney’s fees of $2,000 deemed reasonable by the court. The original judgment was amended to include these penalties and fees, which were affirmed on appeal.

Legal Issues Addressed

Arbitrary and Capricious Conduct in Denial of Compensation

Application: The defendant's refusal to compensate for the thumb injury was deemed arbitrary, unsupported by the record, and led to the imposition of penalties.

Reasoning: The court found that the defendant's failure to provide compensation for the thumb injury was arbitrary and capricious, despite later findings indicating a greater disability.

Awarding of Penalties and Attorney's Fees

Application: The court awarded 12% penalties on overdue benefits and attorney's fees due to the defendant’s unjustified denial of the plaintiff’s claims.

Reasoning: Plaintiff was awarded 12% penalties on the benefits due for the thumb disability, totaling $366, with legal interest from January 31, 1984. Additionally, he was awarded $2,000 in attorney’s fees, determined to be reasonable and appropriate.

Compensation for Partial Disability under LSA-R.S. 23:1221(4)(e)

Application: The plaintiff was awarded benefits for a partial disability of the hand, which was contested based on the extent of disability confirmed by medical reports.

Reasoning: Plaintiff was awarded benefits for a partial disability of his hand under LSA-R.S. 23:1221(4)(e).

Penalties and Attorney’s Fees for Arbitrary Refusal to Pay under R.S. 23:1201.2 and R.S. 22:658

Application: The court imposed penalties and attorney's fees on the defendant for its arbitrary and capricious refusal to pay compensation benefits for the thumb injury.

Reasoning: The central issue is whether this refusal was arbitrary or capricious, given that the defendant had medical reports indicating a partial disability of the plaintiff's thumb but lacked confirmation of a hand disability.