Black v. St. Tammany Parish Hospital

Summary

The Supreme Court of Louisiana held that Louisiana Revised Statute § 46:1063 provides an exclusive and mandatory venue for suits against hospital service districts. That specific provision requires suit in the district's designated domicile and prevails over the general political-subdivision venue provision in § 13:5104(B). The court overruled its contrary holding in White v. Beauregard Memorial Hospital, reversed the court of appeal, and reinstated the trial court's transfer of the action to St. Tammany Parish.

Holdings

1. La. Rev. Stat. § 46:1063 provides an exclusive, mandatory venue for an action against a hospital service district in the parish of the district's designated domicile.
2. When La. Rev. Stat. § 46:1063 conflicts with La. Rev. Stat. § 13:5104(B), the specific provision in § 46:1063 prevails as an exception to the general provision in § 13:5104(B).
3. White v. Beauregard Memorial Hospital is overruled to the extent that it conflicts with the holding that La. Rev. Stat. § 46:1063 controls venue for suits against hospital service districts.

Questions Presented

1. Whether La. Rev. Stat. § 46:1063 provides an exclusive and mandatory venue for actions against a hospital service district.
2. Whether the specific venue provision for hospital service districts in La. Rev. Stat. § 46:1063 controls over the general political-subdivision venue provision in La. Rev. Stat. § 13:5104(B).
3. Whether the court's prior holding in White v. Beauregard Memorial Hospital should be overruled to the extent it treated La. Rev. Stat. § 13:5104(B) as controlling.

Disposition

reversed_and_remanded