Jana Thomas v. Hannah Q Smokehouse, LLC and Twin City Fire Insurance Company

STATE OF LOUISIANA
COURT OF APPEAL, FIRST CIRCUIT

JANA THOMAS NO. 2026 CW 0609
VERSUS

HANNAH Q SMOKEHOUSE, LLC AND

TWIN CITY FIRE INSURANCE
COMPANY JULY 27, 2026

In Re: Hannah Q Smokehouse, LLC and Twin City Fire Insurance
Company, applying for supervisory writs, 19th Judicial
District Court, Parish of East Baton Rouge, No. 716575.

BEFORE : PENZATO, GREENE, AND FIELDS, Ju.

WRIT GRANTED WITH ORDER. We find the district court committed
legal error by failing to comply with La. Code Civ. P. art.
1425(F), which requires the trial court to provide findings of
fact, conclusions of law, and reasons for judgment detailing in
law and fact why a person shall be allowed or disallowed to testify
under La. Code Evid. arts. 702 through 705. The district court’s
oral reasons for its ruling, which denied the Motion in Limine to
Exclude Expert Testimony of Eric Parnell failed to conform to the
requirements of La. Code Civ. P. art. 1425. See Camsoft Data
Systems, Inc. v. Southern Electronics Supply, Inc., 2019-0741 (La.
App. ist Cir. 7/2/19), 2019 WL 2865255, *2 (unpublished). We
therefore vacate the district court’s April 2, 2026 Judgment
denying the motion in limine and remand the matter to the trial
court with instructions to comply with La. Code Civ. P. art.
1425 (F).

COURT OF APPEAL, FIRST CIRCUIT

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