Beatty v. Rigid Constructors — Partial summary judgment reversed because factual disputes remained

Case
Jonas Beatty v. Rigid Constructors, LLC, Cody Fortier, Russ Settoon, and ABC Company
Court
Louisiana Court of Appeal, First Circuit
Judge
Wolfe; Stromberg; Balfour
Date Decided
October 5, 2026
Docket No.
2026 CW 0711
Topics
Summary Judgment; Employment Contracts; Breach of Contract; Supervisory Writs
Source
Read the full opinion

Background

Jonas Beatty sued Rigid Constructors, LLC, Cody Fortier, Russ Settoon, and ABC Company in Louisiana’s 18th Judicial District Court for Pointe Coupee Parish. The dispute included whether Section 3(e) of Beatty’s employment contract had been breached.

Beatty and Rigid Constructors filed competing summary-judgment motions. In a May 5, 2026 judgment, the trial court granted Beatty’s motion for partial summary judgment and denied Rigid Constructors’ motion, determining that Section 3(e) had been breached. Rigid Constructors sought supervisory review.

The Court’s Holding

The Louisiana Court of Appeal, First Circuit, granted the writ in part and denied it in part. It reversed the portion of the judgment granting Beatty partial summary judgment and denied Beatty’s motion.

Applying Louisiana Code of Civil Procedure article 966(A)(3), the court concluded that genuine issues of material fact remained concerning whether Section 3(e) of the employment contract had been breached. Those disputes precluded partial summary judgment. The court denied the writ in all other respects, leaving undisturbed the denial of Rigid Constructors’ summary-judgment motion.

Key Takeaways

  • A court may not grant summary judgment when genuine issues of material fact remain.
  • Unresolved factual questions about whether Section 3(e) was breached required reversal of Beatty’s partial summary judgment.
  • Because the writ was denied in all other respects, Rigid Constructors did not obtain summary judgment in its favor.

Why It Matters

The ruling leaves the contractual-breach issue unresolved rather than deciding it for either side as a matter of law. The parties must continue litigating whether the conduct at issue constituted a breach of Section 3(e).

The decision also illustrates the limited nature of supervisory relief: the appellate court corrected the premature grant of partial summary judgment while declining to disturb the remainder of the trial court’s ruling.

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