essential element claim (Louisiana) · Go Syfert
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essential element claim in Louisiana

50 Louisiana opinions name it 2 courts 1967–2022 2 in the last five years

The cases below were cited by Louisiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (12)

CaseFollowedCited
Townley v. City of Iowagreen
lactapp · 1997 · cited in 10 Louisiana opinions naming this issue, 1998–2012
2 sentences

2012See also Townley v. City of Iowa, 97-493 (La.App. 3 Cir. 10/29/97) , 702 So.2d 323 .

2010See also Townley v. City of Iowa, 97-493 (La.App. 3 Cir. 10/29/97) , 702 So.2d 323 .

210
Alex v. Dr. Xgreen
lactapp · 1997 · cited in 3 Louisiana opinions naming this issue, 2006–2010
2 sentences

2010As such, the burden shifted to Mr. Crochet to "sufficiently establish the existence of proof of an essential element of his claim on which he is to bear the burden of proving at trial." Alex v. Dr. X, 96-1196, p. 4 (La.App. 3 Cir. 3/5/97), 692 So.2d 499, 502 ; La.Code Civ.P. art. 966(C).

2009As such, the burden shifted to Plaintiffs to “sufficiently establish the existence of proof of an essential element of his claim on which he is to bear the burden of proving at trial.” Alex v. Dr. X, 96-1196, p. 4 (La.App. 3 Cir. 3/5/97), 692 So.2d 499, 502 ; La.Code Civ.P. art. 966(C).

13
Haywood v. Louisiana Sugar Cane Productsgreen
lactapp · 1997 · cited in 2 Louisiana opinions naming this issue, 1997–2008
2 sentences

2008Haywood, 692 So.2d 524 .

1997Haywood, 692 So.2d 524 .

12
Westerfield v. LaFleurgreen
la · 1986 · cited in 2 Louisiana opinions naming this issue, 1999–2000
2 sentences

2000In the seminal case of Westerfield v. LaFleur, 493 So.2d 600 (La. 1986), our Supreme Court held that a plaintiff attempting to come within coverage of an uninsured motorist clause need not prove, as an essential element of the claim, that he was actually physically touching the vehicle at the time of the injury.

1999It is not necessary for a plaintiff, to come within coverage of an uninsured motorist clause, to prove, as an essential element of his claim, that he was actually physically touching the car at the time of the injury.” Id. at 603 .

12
Day v. Coca-Cola Bottling Co., Inc.green
lactapp · 1982 · cited in 2 Louisiana opinions naming this issue, 1986–1999
2 sentences

1999The court then cited with approval the case of Day v. Coca-Cola Bottling Company, Inc., 420 So.2d 518, 520 (La.App. 2 Cir.1982): It is not the physical contact with the vehicle that serves as a basis to determine whether a person is injured while alighting from a vehicle but it is the relationship between the person and the vehicle, |r,obviously of time and in distance with regard to the risk of alighting that determines specific coverage.

1986Smith v. Girley, supra ; Day v. Coca-Cola Bottling Company, Inc. 420 So.2d 518 (La.

12
Smith v. Girleygreen
la · 1971 · cited in 2 Louisiana opinions naming this issue, 1982–1986
2 sentences

1986In dicta the Supreme Court said in Smith : "[I]t is not necessary for a plaintiff, to come within coverage of an uninsured motorist clause, to prove, as an essential element of his claim, that he was actually physically touching the car at the time of the injury." 255 So.2d at 751 .

1982Our supreme court has not had occasion to squarely construe the term while alighting from, but has observed "... it is not necessary for a plaintiff, to come within the coverage of an uninsured motorists clause, to prove, as an essential element of his claim, that he was actually physically touching the car at the time of *520 the injury." Smith v. Girley, 260 La. 223 , 255 So.2d 748, 751 (1971).

12
Moresi v. State, Dept. of Wildlife & Fisheriesgreen
la · 1990 · cited in 1 Louisiana opinions naming this issue, 2022–2022
1 sentence

2022See Moresi v. State Through Department of Wildlife and Fisheries, 567 So. 2d 1081, 1095 ( La. 1990).

11
Tomaso v. Home Depot, U.S.A., Inc.green
lactapp · 2015 · cited in 1 Louisiana opinions naming this issue, 2017–2017
1 sentence

2017See Tomaso v. Home Depot, U.S.A., Inc., 14-1467 (LaApp. 1 Cir. 6/5/15), 174 So.3d 679, 682 .

11
730 BIENVILLE PARTNERS v. First Nat. Bankgreen
lactapp · 1992 · cited in 1 Louisiana opinions naming this issue, 2015–2015
1 sentence

2015See 730 Bienville Partners, 596 So.2d at 836 .

11
Samaha v. Raugreen
la · 2008 · cited in 1 Louisiana opinions naming this issue, 2008–2008
1 sentence

2008See Samaha v. Rau, 07-1726 (La.2/26/08), 977 So.2d 880 .

11
State v. Bradfordgreen
la · 1971 · cited in 1 Louisiana opinions naming this issue, 1971–1971
11
State v. Hillsgreen
la · 1971 · cited in 1 Louisiana opinions naming this issue, 1971–1971
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Louisiana. Read the followed side critically anyway.

Also cited on this issue (33)

CaseCitedYears
Babin v. Winn-Dixie Louisiana, Inc. green
la · 2000
2 sentences

2014Babin v. Winn-Dixie Louisiana, Inc., 2000-0078 (La.6/30/00), 764 So.2d 37 ; Cavet v. Louisiana Extended Care Hosp., 47,141 (La.App.2d Cir.5/16/12), 92 So.3d 1122 .

2014Babin v. Winn-Dixie Louisiana, Inc., 2000-0078 (La.6/30/00), 764 So.2d 37 ; Caret v. Louisiana Extended Care Hosp., 47,141 (La.App.2d Cir.5/16/12), 92 So.3d 1122 .

52012–2014
Cavet v. Louisiana Extended Care Hospital green
lactapp · 2012
2 sentences

2014Babin v. Winn-Dixie Louisiana, Inc., 2000-0078 (La.6/30/00), 764 So.2d 37 ; Cavet v. Louisiana Extended Care Hosp., 47,141 (La.App.2d Cir.5/16/12), 92 So.3d 1122 .

2014Babin v. Winn-Dixie Louisiana, Inc., 2000-0078 (La.6/30/00), 764 So.2d 37 ; Caret v. Louisiana Extended Care Hosp., 47,141 (La.App.2d Cir.5/16/12), 92 So.3d 1122 .

32014–2014
Short v. Giffin green
lactapp · 1996
2 sentences

2006The burden thus shifted to Plaintiffs to "sufficiently establish the existence of proof of an essential element of their claim on which they are to bear the burden of proving at trial." Alex v. Dr. X, 96-1196, p. 4 (La.App. 3 Cir. 3/5/97), 692 So.2d 499, 502 (citing Short v. Giffin, 96-0361 (La.App. 4 Cir. 8/21/96) , 682 So.2d 249 , writ denied 96-3063 (La.3/7/97), 689 So.2d 1372 ).

1997Short, 682 So.2d 249 .

21997–2006
Fisher v. Westbank Roofing neutral
lactapp · 1996
2 sentences

2005R.S. 23:1081, the claimant must be tested for drug use immediately after the- accident.” See also Reuben v. Tidewater Marine, 97-521, p. 4 (La.App. 5 Cir. 5/13/98), 712 So.2d 263, 264 , writ denied, 98-1486 (La.9/4/98), 721 So.2d 916 (emphasis added), in which the court stated: “The immediacy of the test is an essential element for the presumption of intoxication.” In Fisher, 670 So.2d 1328 , the employer had requested a drug screen to be performed on the day of the accident, but that request was not carried out until six days later.

2005Even though the delay in testing was not attributable to the employer, the court nonetheless found that “the immediacy requirement of R.S. 23:1081(7)(a) had not been met and, therefore, the presumption was not available.” Id. at 1331 .

21998–2005
Hayes v. Autin green
lactapp · 1996
2 sentences

1997Hayes, 96-287; 685 So.2d 691 .

1997Hayes , 96-287; 685 So.2d 691 .

21997–1997
Roy Bufkin, Jr. v. Felipe's Louisiana, LLC green
la · 2014
1 sentence

2021Bufkin, 171 So.3d at 858 .

12021–2021
Powell v. Gramercy Insurance Co. green
lactapp · 2014
2 sentences

2017Powell v. Gramercy Inc. Co., 13-928 (La.App. 5 Cir. 4/23/14) ; 140 So.3d 324, 326 .

2017Powell v. Gramercy Inc. Co., 13-928 (La.App. 5 Cir. 4/23/14) ; 140 So.3d 324, 326 .

12017–2017
Clark v. J-H-J Inc. green
lactapp · 2013
1 sentence

2016See LSA-C.C.P. art. 966C; Clark, 136 So.3d at 818 .

12016–2016
Farrar v. Hobby green
scotus · 1992
2 sentences

2014Thus, "[wjhen a plaintiff recovers only nominal damages because of his failure to prove an essential element of his claim for monetary relief ..., the only reasonable attorney fee is usually no fee at all.” Id. 506 U.S. at 115 , 113 S.Ct. 566 .

2014Thus, "[wjhen a plaintiff recovers only nominal damages because of his failure to prove an essential element of his claim for monetary relief ..., the only reasonable attorney fee is usually no fee at all.” Id. 506 U.S. at 115 , 113 S.Ct. 566 .

12014–2014
Orgeron on Behalf of Orgeron v. McDonald green
la · 1994
1 sentence

2014In Orgeron v. McDonald, 639 So.2d 224 (La.1994), the court discussed in detail the application of the “course and scope” concept and initially pointed out that an employer is answerable for the damage occasioned by his servant in the exercise of the functions in which the servant is employed.

12014–2014
Lewis v. Pine Belt Multipurpose Community Action Acquisition Agency, Inc. neutral
lactapp · 2014
1 sentence

2014Babin v. Winn-Dixie Louisiana, Inc., 00-0078 (La.06/30/00), 764 So.2d 37 ; Lewis v. Pine Belt Multipurpose Community Action Acquisition Agency, Inc., 48,880 (La.App.2d Cir.05/07/14), 139 So.3d 562 , units denied, 14-0988, 14-1190 (La.08/25/14), 147 So.3d 1120 , 1121.

12014–2014
Price v. Valenti neutral
la · 2014
1 sentence

2014Babin v. Winn-Dixie Louisiana, Inc., 00-0078 (La.06/30/00), 764 So.2d 37 ; Lewis v. Pine Belt Multipurpose Community Action Acquisition Agency, Inc., 48,880 (La.App.2d Cir.05/07/14), 139 So.3d 562 , units denied, 14-0988, 14-1190 (La.08/25/14), 147 So.3d 1120 , 1121.

12014–2014
Klein v. Cisco-Eagle, Inc. green
lactapp · 2003
1 sentence

2012Babin v. Winn-Dixie Louisiana, Inc., 00-0078 (La.6/30/00), 764 So.2d 37 ; Klein v. Cisco-Eagle, Inc., 37,398 (La.App.2d Cir.9/24/03), 855 So.2d 844 .

12012–2012
Short v. Giffin green
la · 1997
1 sentence

2006The burden thus shifted to Plaintiffs to "sufficiently establish the existence of proof of an essential element of their claim on which they are to bear the burden of proving at trial." Alex v. Dr. X, 96-1196, p. 4 (La.App. 3 Cir. 3/5/97), 692 So.2d 499, 502 (citing Short v. Giffin, 96-0361 (La.App. 4 Cir. 8/21/96) , 682 So.2d 249 , writ denied 96-3063 (La.3/7/97), 689 So.2d 1372 ).

12006–2006
Reuben v. Tidewater Marine neutral
lactapp · 1998
1 sentence

2005R.S. 23:1081, the claimant must be tested for drug use immediately after the- accident.” See also Reuben v. Tidewater Marine, 97-521, p. 4 (La.App. 5 Cir. 5/13/98), 712 So.2d 263, 264 , writ denied, 98-1486 (La.9/4/98), 721 So.2d 916 (emphasis added), in which the court stated: “The immediacy of the test is an essential element for the presumption of intoxication.” In Fisher, 670 So.2d 1328 , the employer had requested a drug screen to be performed on the day of the accident, but that request was not carried out until six days later.

12005–2005
Reuben v. Tidewater Marine neutral
la · 1998
1 sentence

2005R.S. 23:1081, the claimant must be tested for drug use immediately after the- accident.” See also Reuben v. Tidewater Marine, 97-521, p. 4 (La.App. 5 Cir. 5/13/98), 712 So.2d 263, 264 , writ denied, 98-1486 (La.9/4/98), 721 So.2d 916 (emphasis added), in which the court stated: “The immediacy of the test is an essential element for the presumption of intoxication.” In Fisher, 670 So.2d 1328 , the employer had requested a drug screen to be performed on the day of the accident, but that request was not carried out until six days later.

12005–2005
Kumpe v. State neutral
lactapp · 1997
1 sentence

1998Kumpe v. State, 97-386 (La.App. 3 Cir. 10/8/97) ; 701 So.2d 498 , writ denied, 98-0050 (La.3/13/98); 712 So.2d 882 .

11998–1998
Kumpe v. State green
la · 1998
1 sentence

1998Kumpe v. State, 97-386 (La.App. 3 Cir. 10/8/97) ; 701 So.2d 498 , writ denied, 98-0050 (La.3/13/98); 712 So.2d 882 .

11998–1998
Fisher v. Westbank Roofing neutral
la · 1996
1 sentence

1998Fisher v. Westbank Roofing, 95-964 (La.App. 5 Cir. 2/27/96) , 670 So.2d 1328 , writ denied, 96-0809 (La.5/10/96), 672 So.2d 926 .

11998–1998
Campbell v. DEPTARTMENT OF TRANSP. & DEV. green
la · 1995
1 sentence

1996E.g., Campbell v. DOTD, 94-1052 at 5-6 (La.1-17-95), 648 So.2d 898, 901 .

11996–1996
Hazen Paper Co. v. Biggins green
scotus · 1993
11995–1995
Acme Refrigeration of Baton Rouge, Inc. v. Whirlpool Corporation & Heil-Quaker Corporation green
ca5 · 1986
11995–1995
United Transportation Union v. Maine Central Railroad green
scotus · 1986
11995–1995
Acme Refrigeration of Baton Rouge, Inc. v. Whirlpool Corp. green
scotus · 1986
11995–1995
Stang v. United States District Court for the Central District of California green
scotus · 1986
11995–1995
New Jersey v. T. L. O. green
scotus · 1985
11994–1994
Bloxom v. Bloxom green
la · 1987
11990–1990
Mella v. Continental Emsco green
la · 1966
11980–1980
Wall v. Sun Insurance neutral
la · 1966
11980–1980
Wall v. Sun Insurance Co. of New York neutral
lactapp · 1966
11980–1980
Elledge v. Warren green
lactapp · 1972
11977–1977
Hendricks v. American Employers Insurance Co. green
lactapp · 1965
11971–1971
Northwestern Mutual Fire Association v. Allain green
la · 1954
11967–1967

Statutes the citing opinions construe

LA § La. Rev. Stat. § 9:2800.6 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NC 401 (1977–2026) TN 391 (1966–2026) CA 177 (1922–2026) TX 168 (1920–2026) IN 124 (1897–2024) MA 97 (1984–2026) MS 93 (1963–2026) OH 90 (1872–2026) ND 75 (1984–2025) WA 68 (1931–2026) NY 68 (1952–2025) GA 60 (1924–2025) IL 54 (1883–2026) AR 51 (1953–2025) LA 50 (1967–2022) WY 47 (1975–2026) MO 41 (1909–2024) MI 41 (1976–2026) AZ 40 (1966–2025) FL 38 (1951–2022) AL 32 (1978–2018) CT 28 (1972–2022) WI 28 (1951–2025) ID 26 (1965–2026) ME 23 (1982–2025) MN 22 (1924–2014) IA 22 (1915–2024) PA 20 (1900–2022) NM 17 (1967–2026) SC 17 (1924–2026) DE 17 (1941–2026) UT 16 (1994–2026) NJ 15 (1984–2023) MT 11 (2000–2026) KY 9 (1929–2024) OK 9 (1937–2009) SD 9 (1946–2016) RI 9 (1984–2026) NV 9 (1986–2022) MD 8 (1966–2024) NE 8 (1942–2023) KS 8 (1994–2026) HI 8 (1984–2018) OR 8 (1922–2010) WV 7 (1982–2025) CO 7 (1981–2025) VT 6 (2010–2025) DC 6 (1964–2021) VA 5 (1989–2023) NH 4 (1996–1999) VI 3 (2013–2023) AK 3 (1989–1998)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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