Jared Guidry And Leigha Woods v. State Farm Mutual Automobile Insurance Company

Supreme Court of Louisiana
November 10, 2021
Chief Deputy Clerk of Court
For the Court
The Supreme Court of the State of Louisiana
JARED GUIDRY AND LEIGHA WOODS
VS.
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY
No. 2021-C-00808
_ _ _ _
_ _
IN R
E: Jared Guidry - Applicant Plaintiff; Leigha Woods - Applicant Plaintiff;
Applying For Writ Of Certiorari, Parish of Jefferson, 24th Judicial District Court
Number(s) 792-598, Court of Appeal, Fifth Circuit, Number(s) 21-C-12;
_ _ _ _ _ _
November 10, 2021
Writ application granted. See per curiam.
Weimer, C.J., dissents and would grant and docket.
JDH
SJC
JTG
WJC
JBM
PDG
11/10/2021 "See News Release 044 for any Concurrences and/or Dissents."

SUPREME COURT OF LOUISIANA
No. 2021-C-00808
JARED GUIDRY AND LEIGHA WOODS
VS.
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY
On Writ of Certiorari to the Court of Appeal, Fifth Circuit, Parish of Jefferson
PER CURIAM
Writ granted. Plaintiffs filed this suit alleging defendant breached an
insurance contract by failing to tender uninsured or underinsured motorist ( UM)
benefits in response to a formal demand. The alleged cause of action arose after the
expiration of the limited period of time granted plaintiffs to amend their petition in
a previous proceeding, which was dismissed with prejudice pursuant to defendant’s
exception of no cause of action . See Guidry v. State Farm Mutual Automobile
Insurance Company, 18-275 (La. App. 5 Cir. 12/27/18), 263 So. 3d 943, 948, writ
denied, 19-0223 (La. 5/20/19), 272 So. 3d 535 ( Guidry I). Defendant asserts the
judgment in Guidry I bars the present suit under res judicata.
The doctrine of res judicata is stricti juris; any doubt must be resolved against
its application. See Kelty v. Brumfield, 633 So. 2d 1210, 1215 (La.1994). The trial
court found “exceptional circumstances” warranted relief from res judicata pursuant
to La. R. S. 13:4232A(1) . This statutory exception gives the court discretion to
balance the principle of res judicata with the interests of justice. See La. R.S.
13:4232, Comment --1990; Oleszkowicz v. Exxon Mobil Corp. , 14 -0256 (La.
12/9/14), 156 So. 3d 645, 647. Because plaintiffs’ alleged cause of action arose after
the opportunity to amend the petition in Guidry I expired, application of res judicata
will effectively deprive plaintiffs of any opportunity to pursue it. In the interest of
justice, these exceptional circumstances warrant relief from the res judicata effect
11/10/21

2

of the Guidry I judgment. The court of appeal erred in reversing the trial court’s
judgment.1
COURT OF APPEAL JUDGMENT REVERSED ; TRIAL COURT
JUDGMENT REINSTATED; CASE REMANDED.

1 In reaching this conclusion, we express n o opinion on the correctness of the holding in
Guidry I that a plaintiff , to state a c ause of action for UM benefits , must allege the UM insurer
breached the insurance contract. That issue is not before the court.