Summary
The United States District Court for the Middle District of Louisiana grants State Farm’s motion for summary judgment in Jamie D’Amico’s bad-faith insurance action. Applying Louisiana res judicata law, the Court concludes that the bad-faith claims arose from the same automobile accident and uninsured/underinsured motorist coverage dispute as an earlier action between the parties and were barred by the final judgment in that action. The Court also disregards Plaintiff’s deficient opposing statement of material facts under the applicable local rules.
Court
United States District Court for the Middle District of Louisiana
Jurisdiction
United States District Court for the Middle District of Louisiana
Decision date
May 26, 2026
Docket number
24-899-JWD-RLB; 3:24-cv-00899
Disposition
dismissed
Questions Presented
- Whether Louisiana res judicata barred D’Amico’s second action for insurance bad-faith claims because those claims existed before final judgment in the first action and arose from the same transaction or occurrence.
- Whether the first and second actions arose from the same transaction or occurrence even though the first action involved the underlying UM contract claim and the second involved statutory bad-faith claims.
- Whether Plaintiff’s failure to comply with the Middle District of Louisiana’s summary-judgment briefing and statement-of-facts rules permitted the court to disregard her opposing statement and deem Defendants’ properly supported facts admitted for summary-judgment purposes.
Holdings
- Louisiana res judicata barred D’Amico’s statutory bad-faith claims because the prior judgment was valid and final, involved the same parties, the bad-faith claims existed when final judgment was entered, and the claims arose out of the same transaction or occurrence as the first action.
- The distinction between contractual UM claims and statutory bad-faith claims did not prevent application of res judicata because Louisiana res judicata turns on whether the actions arise from the same transaction or occurrence, not whether the legal causes of action are identical.
- The court disregarded Plaintiff’s opposing statement of material facts because it failed to admit, deny, or qualify Defendants’ facts and contained no record citations, and the court deemed Defendants’ properly supported facts admitted for summary-judgment purposes.
Court Document
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