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Little v. Mangano

Citations: 683 So. 2d 855; 1996 La. App. LEXIS 2318; 1996 WL 608575Docket: No. 96-C-2232

Court: Louisiana Court of Appeal; October 23, 1996; Louisiana; State Appellate Court

Narrative Opinion Summary

In this case, the relator contested the trial court's denial of an exception of prescription regarding a redhibition claim filed by the plaintiffs. The plaintiffs purchased ostrich chicks in 1993, which were later found to be unsuitable for breeding. They filed a redhibition action in February 1995, beyond the typical two-month prescriptive period for animals under Louisiana Civil Code Article 2535. The court examined whether the plaintiffs' claim was timely, given their continuous efforts to resolve the defect with the seller. The court noted that under Louisiana law, if the prescriptive period appears expired, the burden shifts to the plaintiffs to prove interruption or suspension of prescription. In this instance, the plaintiffs demonstrated ongoing attempts to remedy the defect through communication and potential solutions, which the court recognized as interrupting the prescription period. Consequently, despite the initial misunderstanding regarding the applicable prescriptive period, the court upheld the trial court's decision to deny the exception of prescription, affirming the plaintiffs' right to proceed with their claim.

Legal Issues Addressed

Burden of Proof When Prescription Period Has Expired

Application: The court shifted the burden to the plaintiffs to show that the prescription was interrupted due to attempts to rectify the defect.

Reasoning: If the petition indicates that the prescription period has expired, the burden shifts to the plaintiff to demonstrate that the prescription was suspended, interrupted, or renounced.

Court's Assessment of Continuous Attempts to Resolve Issues

Application: The court affirmed that the plaintiffs' ongoing efforts to address the defect interrupted the prescription period, supporting the denial of the exception.

Reasoning: The court found that the Littles made continuous attempts to resolve the issue, thereby interrupting the prescription period.

Redhibition Claim Prescription Period under Louisiana Civil Code Article 2535

Application: The court considered whether the plaintiffs filed the redhibition claim within the prescribed timeframe, acknowledging the two-month period for animals.

Reasoning: Under Louisiana Civil Code Article 2535, claims for redhibition of animals must be filed within two months of sale or discovery of a defect.

Suspension of Prescription Period Due to Attempts to Remedy

Application: Continuous efforts by the plaintiffs to resolve the defect through communication and potential exchanges suspended the prescription period.

Reasoning: The court noted that attempts to remedy the defect can suspend the prescription period until such attempts are abandoned.