Caillier v. Strictly Stars Touring, 195 So. 3d 1237

Plaintiff Robert Caillier sued multiple parties after a booked performance was cancelled and sought return of an unrefunded deposit ($12,500) plus out-of-pocket expenses ($16,000) and lost profits ($150,000).
Defendants failed to answer; Caillier obtained a preliminary default and a hearing to confirm the default; a written judgment was signed awarding the deposit and expenses against five named entities/people (Strictly Stars, Harrington, I Book Stars, Future, and Epic).
The judgment expressly denied the lost-profits claim "at this time," suggesting the court left that issue open.
The judgment did not specify whether defendants were jointly/solidarily liable or allocate amounts among them; Epic was included in the decree though not named in the petition.
Epic Records and Future filed devolutive appeals; the appellate court issued a rule to show cause whether the appeals should be dismissed for (1) taking appeal from a partial judgment not designated final under La. C.C.P. art. 1915(B) and (2) lacking required decretal language.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the default judgment is immediately appealable or a partial judgment requiring La. C.C.P. art. 1915(B) certification	Caillier treated the judgment as resolving some claims but left lost-profits open; argued proceedings were appropriate to confirm default	Epic/Future argued a confirmed default judgment is a final, appealable judgment under La. C.C.P. arts. 1841 and 2083	Judgment was a partial judgment because it denied lost profits "at this time;" art. 1915(B) required an express determination and designation of finality before immediate appeal; no such designation was in record, so appeal premature
Whether the judgment contains sufficient decretal language to be a valid final judgment	Caillier obtained an award but the decree named multiple defendants	Appellants argued the judgment was final/appealable as entered	Judgment lacked necessary decretal language: it did not specify who owes what (joint/solidary or individual amounts); appeals dismissed for lack of decretal clarity

State v. White, 921 So.2d 1144 (La. App. 3 Cir. 2006) (final appealable judgment must contain decretal language)
Apartment Redevelopment Corp. v. Polkey, 800 So.2d 968 (La. App. 5 Cir. 2001) (default judgment that does not dispose of all claims can be a partial judgment subject to art. 1915)
Laviolette v. DuBose, 983 So.2d 160 (La. App. 5 Cir. 2008) (default judgments not adjudicating all claims may be subject to art. 1915(B))
Seaman v. Seaman, 54 So.3d 756 (La. App. 3 Cir. 2010) (art. 1915(B) generally applies but some judgments fall outside its scope)
Input/Output Marine Sys., Inc. v. Wilson Greatbatch Tech., Inc., 52 So.3d 909 (La. App. 5 Cir. 2010) (judgment must be precise and decree must state specific relief without reference to extrinsic sources)
Dietz v. Dietz, 128 So.3d 1215 (La. App. 3 Cir. 2013) (judgment lacking necessary decretal language is not final)

Decision: Appeals dismissed without prejudice for lack of jurisdiction; remanded for further proceedings consistent with opinion.