Blake v. City of Port Allen, 167 So. 3d 781

City of Port Allen employees replaced a residential water meter on Feb 8, 2011; homeowner Ronnie Blake left while work was ongoing and returned ~2 hours later to find extensive flooding from a failed attic pipe union. Blake immediately shut off the water and later sued the City for negligence.
Blake presented an engineering expert who opined the City workers turned water off/on improperly, creating pressure/vacuum that caused the rubber fitting to fail.
The City presented testimony about a protocol requiring employees to check the meter (including a sensitive "cheater" dial) to detect any post‑work leaks and stipulated its workers followed the protocol.
The City’s mechanical engineer attributed the leak to an aged gasket and a pipe bend that allowed the gasket to shift under normal pressure fluctuations.
Trial court found the leak developed while the City was replacing the meter and that the workers either failed to follow the meter‑checking protocol or the replacement meter was defective; awarded Blake $20,000 in damages.
On appeal the City challenged (1) breach and causation findings, (2) failure to assign comparative fault to Blake, and (3) sufficiency of the $20,000 damages award; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether City breached duty and its conduct legally/actually caused the flooding	City employees failed to follow shut‑off/turn‑on and meter‑check protocol, causing the union to fail	Leak could have occurred from aged gasket/pipe condition regardless of workers' conduct; expert supports nonnegligent cause	Affirmed: factual record supports finding workers failed to detect leak or meter failed; that failure was a cause‑in‑fact and proximate cause of damage
Whether comparative fault should be allocated to Blake for plumbing condition	Blake had no notice of any defect and promptly turned off water on discovery	City: Blake was responsible for private service line maintenance and deterioration caused the leak	Affirmed: trial court permissibly credited evidence that plumbing condition did not establish Blake’s fault; no manifest error in assigning no comparative fault
Whether $20,000 award for damages is supported by evidence	Blake testified to specific repair costs (corroborated by photos); many receipts excluded for discovery violations but testimony was uncontradicted	City: only $2,389.12 in admitted invoices; remaining amounts unsupported by receipts	Affirmed: court may rely on uncontradicted testimony of amounts actually paid and award reasonable property damages; $20,000 not an abuse of discretion

Brewer v. J.B. Hunt Transport, Inc., 35 So.3d 230 (La. 2010) (articulates five‑element duty‑risk negligence framework)
Hanks v. Entergy Corp., 944 So.2d 564 (La. 2006) (standard for reviewing trial court fact findings; manifest error rule)
Stobart v. State, Through DOTD, 617 So.2d 880 (La. 1993) (deference to factfinder where testimony conflicts)
Rando v. Anco Insulations Inc., 16 So.3d 1065 (La. 2009) (legal cause involves foreseeability and association to risk)
Adams v. Rhodia, Inc., 983 So.2d 798 (La. 2008) (deference where factfinder chooses between two permissible views, including expert conflicts)
Granger v. Christus Health Central Louisiana, 144 So.3d 736 (La. 2013) (cause‑in‑fact standard; substantial factor test when concurrent causes exist)
Coleman v. Victor, 326 So.2d 344 (La. 1976) (uncontradicted testimony admitted without objection may suffice to prove repair costs)
Wainwright v. Fontenot, 774 So.2d 70 (La. 2000) (plaintiff bears burden to prove damages resulting from defendant’s fault)