Background
Joel Gangi d/b/a Gangi, Inc., along with other plaintiffs, brought claims against several defendants, including Star Transport Logistics, Inc. The matter arose in consolidated proceedings in the 18th Judicial District Court for West Baton Rouge Parish.
Before trial, the plaintiffs sought to exclude evidence and questioning concerning insurance payments and subrogation claims involving equine insurance policies. The district court denied that portion of their omnibus motion in limine, permitting a defendant to refer to the policies and question witnesses about them.
The Court’s Holding
The Louisiana First Circuit granted supervisory writs and reversed the portion of the September 21, 2026 judgment that denied the plaintiffs’ request to exclude the insurance-related evidence.
The court held that the collateral source rule prevents a tortfeasor from benefiting from insurance proceeds received by an injured plaintiff through sources independent of the tortfeasor’s procurement or contribution. It also cited Louisiana Code of Evidence article 411. Accordingly, evidence regarding the equine policies is excluded at trial.
Key Takeaways
- A defendant generally may not use a plaintiff’s independently obtained insurance benefits to reduce tort recovery.
- The collateral source rule protects a plaintiff’s foresight in purchasing insurance.
- Evidence concerning the equine insurance policies may not be introduced at trial.
Why It Matters
The ruling reinforces that insurance payments from collateral sources ordinarily cannot be used to benefit an alleged tortfeasor. In Louisiana tort trials, parties should closely assess proposed insurance evidence under the collateral source rule and Evidence Code article 411.