Hotel Management of New Orleans (“HMNO”) owned and operated the French Market Inn. A sprinkler head located in the hotel was triggered during Mardi Gras, which caused a water leak and flooding in the store two floors below. The storeowner claimed water leaked into its store for approximately two hours. During that time, HMNO did not try to turn off the sprinkler but instead waited for the fire department to turn off the sprinkler. This caused damage to the store.
State Farm insured the storeowner and paid the storeowner approximately $41k under its policy. State Farm then filed a lawsuit against HMNO and its insurer, Companion Property, and Casualty Insurance Company, seeking repayment of the $41k it paid to the storeowner under its policy. The trial court found in favor of State Farm and ordered HMNO and Companion to pay the stipulated damages of $41k. HMNO and Companion appealed, arguing that the trial court erred in finding that HMNO knew or should have known the sprinkler was defective, HMNO employees were negligent, and denying HMNO’s motion for involuntary dismissal.
In civil cases such as this, an appellate court cannot set aside a factual finding unless the trial court’s finding is clearly wrong or manifestly erroneous. An appellate court also applies the manifest error standard in reviewing a motion for involuntary dismissal. Under La. C.C. art. 2316, a person is responsible for damage caused by their negligence.
Here, there was no dispute that the water that leaked from HMNO’s sprinkler damaged the store. The parties also agreed to damages of $42k. In Louisiana, a business does not have a duty to protect nearby buildings from water from a fire sprinkler system. However, there is a duty to use reasonable care to avoid injuring others. Here, the evidence showed that HMNO’s employees followed the appropriate procedure in requiring the fire department to turn off the activated sprinkler. State Farm did not present any evidence that requiring the fire department to turn off the sprinkler created an unreasonable risk of harm. Further, there was no evidence that the sprinkler was defective. Therefore, the appellate court found that State Farm did not establish HMNO was negligent.
HMNO and its insurer also argued that the trial court erred in denying their motion for involuntary dismissal. Under La. C.C.P art. 1672(B), a defendant can move for an involuntary dismissal following a bench trial where the plaintiff has not shown a right to relief. Because the appellate court found the trial court committed manifest error in finding in favor of State Farm, it was also not entitled to an involuntary dismissal.
In the case of State Farm v. Hotel Management of New Orleans, the appellate court reversed the trial court’s ruling and found that the hotel, HMNO, was not negligent for the water damage suffered by the store. While the hotel’s sprinkler malfunctioned during Mardi Gras, causing water leakage and subsequent damage, the evidence demonstrated that HMNO’s employees followed standard procedures by waiting for the fire department to handle the situation.
Moreover, there was no evidence of a defective sprinkler or any unreasonable risk of harm created by the hotel’s actions. As a result, the appellate court found in favor of HMNO and its insurer, Companion Property, and Casualty Insurance Company, denying the repayment of damages sought by State Farm. When faced with property damage, seeking the guidance of a knowledgeable attorney can help you understand your legal options and pursue appropriate remedies to recover for the losses you have suffered.
Additional Sources: State Farm Fire and Casualty Co. v. Hotel Management of New Orleans, LLC
Written by Berniard Law Firm
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