Louisiana Court of Appeal, 2025

Todd Blair and Vanessa Blair v. Southern Farm Bureau Insurance Company, Industrial Support System, Inc.

Todd Blair and Vanessa Blair v. Southern Farm Bureau Insurance Company, Industrial Support System, Inc.
Louisiana Court of Appeal · Decided October 31, 2025

Todd Blair and Vanessa Blair v. Southern Farm Bureau Insurance Company, Industrial Support System, Inc.

Opinion

STATE OF LOUISIANA COURT OF APPEAL, FIRST CIRCUIT TODD BLATR AND VANESSA BLAIR NO. 2025 CW 0624 VERSUS LOUISIANA FARM BUREAU CASUALTY INSURANCE COMPANY, INDUSTRIAL SUPPORT SYSTEM, INC., ROD BRAUD AND JEFFERY DIEZ, IN HIS INDIVIDUAL AND OFFICIAL CAPACITY AS OFFICER OCTOBER 31, 2025 OF INDUSTRIAL SUPPORT SYSTEM, INC. In Re: Industrial Support System, Inc., applying for supervisory writs, 23rd Judicial District Court, Parish of Ascension, No. 134617.

BEFORE: LANIER, WOLFE, AND HESTER, JJ.

WRIT GRANTED. The district court’s April 9, 2025 judgment which denied the motion for summary judgment filed by defendant, Industrial Support System, Inc., is reversed. For liability to attach under La. Civ. Code art. 2317.1, the plaintiff must prove that: (1) the property that caused the damage was in the custody of the defendant; (2) the property had a condition that created an unreasonable risk of harm; (3) the unreasonably dangerous condition was a cause in fact of the resulting injury; and (4) the defendant had actual or constructive knowledge of the risk.

Batiste v. Erin Covington, LP, 2019-0261 (La. App. lst Cir. 12/11/19), 291 So.3d 710, 714-15. Plaintiffs alleged that decedent, Devin Blair, was hired to inspect a tree on the property and cut the felled limbs and/or the remainder of the damaged tree following a storm. We find defendant had no duty to warn Devin Blair of, or protect him from, hazards relating to the very condition which he was hired to address and remedy. McCarroll v. Prime Cut Law Care & Tractor Work, LLC, 2010-1638 (La. App. Ist Cir. 3/25/11), 2011 WL 1104132, at *5. See also Pryor v. CCRR Properties, LLC, 2025-254 (La. App. 3d Cir. 10/22/25), -- So.3d - -, 2025 WL 2967572. Accordingly, the motion for summary judgment is granted, and plaintiffs’ claims against defendant, Industrial Support System, Inc., are dismissed. wi EW CHA COURT OF APPEAL, FIRST CIRCUIT DEPUTY CLERK OF COURT FOR THE COURT

Case-law data current through December 31, 2025. Source: CourtListener bulk data.