Cassandra Broussard v. Start Corporation Division (3)

Summary

The United States District Court for the Eastern District of Louisiana denied Plaintiff Cassandra Broussard’s motion for reconsideration of the dismissal of certain claims against Start Corporation Division (3). The court held that Federal Rule of Civil Procedure 54(b), rather than Rule 59(e), governed reconsideration of the interlocutory dismissal order. The court found no persuasive justification to reconsider its prior dismissal of claims for intentional infliction of emotional distress, negligent supervision, and violation of the Louisiana Employment Discrimination Law.

Holdings

1. Federal Rule of Civil Procedure 59(e) does not apply to a motion seeking reconsideration of an interlocutory ruling; Federal Rule of Civil Procedure 54(b) governs instead.
2. Reconsideration was unwarranted because Plaintiff presented no persuasive justification for changing the prior ruling and did not establish error.
3. The court rejected Plaintiff's argument that the Louisiana Workers' Compensation Act's exclusivity provision applies only to physical workplace injuries.

Questions Presented

1. Whether Federal Rule of Civil Procedure 59(e) governs a motion seeking reconsideration of an interlocutory ruling.
2. Whether Plaintiff presented sufficient grounds under Federal Rule of Civil Procedure 54(b) to reconsider the prior dismissal of claims for intentional infliction of emotional distress, negligent supervision, and violation of the Louisiana Employment Discrimination Law.
3. Whether the Louisiana Workers' Compensation Act's exclusivity provision applies only to physical workplace injuries.

Disposition

other