Trustee for Debtor in bankruptcy, Offshore Specialty Fabricators, LLC v. Stephen J. Williams

STATE OF LOUISIANA
COURT OF APPEAL, FIRST CIRCUIT

TRUSTEE FOR DEBTOR IN NO. 2026 CW 0686
BANKRUPTCY, OFFSHORE
SPECIALTY FABRICATORS, LLC

VERSUS
STEPHEN J. WILLIAMS, ET AL SEPTEMBER 14, 2026
In Re: Trustee for Debtor in Bankruptcy, Offshore Specialty

Fabricators, LLC, applying for supervisory writs, 32nd
Judicial District Court, Parish of Terrebonne, No.
187130.

BEFORE : THERIOT, LANIER, HESTER, GREENE, AND EDWARDS, JJ.

WRIT GRANTED. The portion of the trial court's March 26, 2026
judgment which granted, Defendants’, Stephen J. Williams; Alliance
Heavy Lift, LLC; Alliance Energy Services, LLC; and Alliance
Offshore, LLC, Exception of No Cause of Action is reversed. The
function of an exception raising the objection of no cause of
action is to test the legal sufficiency of the petition by
determining whether the law affords a remedy on the facts alleged
in the pleading. Global Marketing Solutions, L.L.C. v. Blue Mill
Farms, Inc., 2018-0093 (La. App. lst Cir. 11/6/18), 267 So.3d 96,
99. No evidence may be introduced to support or controvert the
objection that the petition fails to state a cause of action, and
all well-pleaded allegations of fact are accepted by the court as
true. Id. The Louisiana Supreme Court recognized for the first
time, a tortious interference with contract claim in 9 to 5
Fashions, Inc. v. Spurney, 538 So.2d 228 (La. 1989), years before
Louisiana recognized LLC’s. As the elements and law set forth in
9 to 5 Fashions, Inc. v. Spurney were confined to the time it was
decided, the rationale rather than vocabulary of 9 to 5 Fashions,
Inc. v. Spurney, should be considered when determining if a cause
of action for tortious interference exists. See Communication &
Information Resources, Inc. v. Expressions Acquisition Corp., 95-
1070 (La. App. 5th Cir, 5/15/96), 675 So.2d 1164; Active Solutions,
L.L.C. v Dell, Ine., 2010-1590 (La. App. 4th Cir. 7/21/11), 73
So.3d 934, 947. Accordingly, we find that Plaintiff's, Trustee for
Debtor in Bankruptcy, Offshore Specialty Fabricators, LLC,
pleadings state a cause of action for tortious interference with
contract against the Defendants. Therefore, Defendants’ Exception
of No Cause of Action is denied.

MRT
WIL
CHH
BDE

Greene, J., dissents and would deny the writ.