Narrative Opinion Summary
The Louisiana Supreme Court has remanded the case for reconsideration regarding Duckworth-Woods' entitlement to a credit for Social Security Disability Benefits paid to employee Henry Lettellier. The previous opinion affirmed the trial court's decision allowing the offset based on the precedent established in Garrett. However, following the Supreme Court's ruling in Al Johnson Construction Co. v. Pitre, which overruled Garrett, it has been determined that employers are not entitled to such offsets under La.Rev.Stat. 23:1225(0). Consequently, Duckworth-Woods is not permitted to claim an offset for Social Security Disability Benefits, as these do not constitute benefits under disability benefit plans. The trial court's judgment allowing the credit is reversed, and a new judgment is issued in favor of Lettellier, confirming that Duckworth-Woods has no right to an offset.
Legal Issues Addressed
Entitlement to Credit for Social Security Disability Benefitssubscribe to see similar legal issues
Application: The case was remanded for reconsideration of Duckworth-Woods' entitlement to a credit for Social Security Disability Benefits paid to the employee, which was initially allowed based on precedent.
Reasoning: The Louisiana Supreme Court has remanded the case for reconsideration regarding Duckworth-Woods' entitlement to a credit for Social Security Disability Benefits paid to employee Henry Lettellier.
Interpretation of La.Rev.Stat. 23:1225(0)subscribe to see similar legal issues
Application: Under the statute, employers are not entitled to offsets for Social Security Disability Benefits as they do not qualify as benefits under disability benefit plans.
Reasoning: Consequently, Duckworth-Woods is not permitted to claim an offset for Social Security Disability Benefits, as these do not constitute benefits under disability benefit plans.
Overruling of Precedent in Disability Benefit Offsetssubscribe to see similar legal issues
Application: The Supreme Court's ruling in Al Johnson Construction Co. v. Pitre overruled the previous precedent set by Garrett, affecting the trial court's decision.
Reasoning: The previous opinion affirmed the trial court's decision allowing the offset based on the precedent established in Garrett. However, following the Supreme Court's ruling in Al Johnson Construction Co. v. Pitre, which overruled Garrett, it has been determined that employers are not entitled to such offsets under La.Rev.Stat. 23:1225(0).
Reversal of Trial Court’s Judgment on Offsetssubscribe to see similar legal issues
Application: The trial court's judgment allowing Duckworth-Woods a credit for Social Security Disability Benefits was reversed, confirming that no offset is permissible.
Reasoning: The trial court's judgment allowing the credit is reversed, and a new judgment is issued in favor of Lettellier, confirming that Duckworth-Woods has no right to an offset.