Castille v. St. Martin Parish School Board
190 So. 3d 1225
La. Ct. App.2016Background
- Gerald Castille, a tenured St. Martin Parish school bus driver since 1977, was reassigned in 2008 to a combined Levee/Portage route after the School Board reconfigured routes to reduce "dead miles."
- Assignment methodology used proximity of drivers’ homes to route starts instead of statutorily mandated seniority/tenure procedures (La.R.S. 17:493.1 and local rules).
- At a public meeting drivers were told routes were "not written in stone" and could be "tweaked" after a trial period; Castille relied on this and requested reassignment after two weeks but was denied until 2011.
- Castille sued (2009) asserting breach of contract (tenure/seniority rights), detrimental reliance, and damages for worsened anxiety/depression; trial court found a statutory tenure violation and awarded lost pay but dismissed breach of contract, detrimental reliance, and nonpecuniary damages.
- The appellate court found legal error in dismissing the contractual/quasi‑contractual claims, reversed dismissal of breach of contract and detrimental reliance, rejected nonpecuniary damages, and awarded $75,000 for exacerbation of anxiety/depression caused by the bad‑faith breach.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether School Board breached contractual employment obligations by assigning routes without using tenure/seniority | Castille: Tenure/seniority statute and local rules are part of his employment contract; assignment based on proximity breached contract | School Board: Reassignment saved fuel and treated drivers equally (same pay), so seniority need not govern; drivers could attend meetings to protect rights | Held: Breach of contract — Board violated La.R.S. 17:493.1 and its rules; appellate review de novo on legal error, judgment for Castille |
| Whether detrimental reliance claim (promise of post‑trial adjustments) was actionable | Castille: Committee’s statements that routes could be adjusted induced him to accept trial placement and not pursue other remedies; he reasonably relied and suffered detriment | School Board: Statements were nonbinding, drivers had opportunity to participate in process | Held: Detrimental reliance proven — representation, justifiable reliance, and detrimental change established |
| Whether workers’ compensation bars Castille’s recovery for claimed emotional/medical harms | School Board: Injuries arise from employment and are therefore exclusively within workers’ compensation scheme | Castille: Claims are contractual/quasi‑contractual (not tort) and thus not precluded by workers’ comp exclusivity | Held: Workers’ compensation does not preclude Castille’s contractual/quasi‑contractual claims; trial court erred on this point |
| Entitlement to nonpecuniary and bad‑faith damages; measure of damages | Castille: Seniority protections intended to satisfy nonpecuniary interests; seeks compensation for emotional harm and related suffering | School Board: Employment contract is pecuniary/service contract; nonpecuniary damages inappropriate; any damages should be limited/foreseeable | Held: Nonpecuniary damages denied (employment contract not aimed to gratify moral interests); but Board acted in bad faith so liable for all direct damages — awarded $75,000 for aggravated anxiety/depression |
Key Cases Cited
- Rosell v. ESCO, 549 So.2d 840 (La. 1989) (standard for appellate review of factual findings)
- Stobart v. State, DOTD, 617 So.2d 880 (La. 1993) (manifest error review explained)
- Evans v. Lungrin, 708 So.2d 731 (La. 1998) (legal error interdicting fact-finding permits de novo review)
- Thorne v. Monroe City School Bd., 542 So.2d 490 (La. 1989) (tenure statutes create exception to at‑will employment for teachers and bus drivers)
- Pizzolato v. State through Bd. of Elementary & Secondary Educ., 452 So.2d 264 (La. App. 1 Cir. 1984) (statutory tenure law read into bus driver employment contracts)
- Luther v. IOM Co. LLC, 130 So.3d 817 (La. 2013) (elements required to prove detrimental reliance)