Gerald Castille v. St. Martin Parish School Board
2017 La. LEXIS 550
| La. | 2017Background
- Gerald Castille, a tenured St. Martin Parish school bus driver since 1977, was reassigned in 2008 to a consolidated Levee–Portage route after the School Board redrew routes to reduce diesel costs.
- The transportation committee that redrew routes did not consider driver seniority; Castille objected, tried the route, reported problems, and experienced worsened anxiety/depression until obtaining a different route in 2011.
- Castille sued, alleging the School Board violated La. R.S. 17:493.1 (seniority/tenure rights), breached the implied employment contract, acted in bad faith, and caused non‑pecuniary harm; tort claims were prescribed.
- The district court found a statutory violation and awarded economic damages (lost pay and increased non‑passenger miles) but dismissed contract and non‑pecuniary claims as barred by workers’ comp exclusivity.
- The court of appeal reversed the dismissal of contractual claims, found a contract breach, held the breach was in bad faith, and awarded $75,000 for acceleration of Castille’s anxiety/depression.
- The Louisiana Supreme Court affirmed the breach finding but reversed the award of bad‑faith contractual damages, holding the Board’s conduct was at most negligent/bad judgment, not bad faith under La. Civ. Code art. 1997.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the School Board breached the employment contract/tenure rights by ignoring seniority in the 2008 reassignments | Castille: statute and tenure protections were read into his contract; failing to consider seniority breached the contract | School Board: reassignments were for legitimate cost‑saving route efficiency; seniority was considered only if feasible | Breach: Yes—Court agrees seniority was not considered and the contract was breached |
| Whether the breach constituted "bad faith" under La. Civ. Code art. 1997 | Castille: the Board intentionally ignored the statute and its own policies, amounting to a deliberate refusal to perform | School Board: acted to reduce fuel costs; decision was negligent or bad judgment, not intentional dishonesty or malice | Bad faith: No—majority holds conduct was not intentional/malicious, so art. 1997 bad‑faith damages do not apply |
| Whether non‑pecuniary/mental‑injury damages from alleged contractual bad faith are recoverable | Castille: seeks recovery for acceleration of anxiety/depression caused by breach | School Board: denies bad faith and contends remedies are limited; tort claims prescribed/exclusive remedy issues | Recoverable non‑pecuniary damages for breach in bad faith: Reversed—no bad‑faith finding, so $75,000 award vacated |
| Scope of workers’ compensation exclusivity vs. contractual remedies | Castille: contractual and detrimental reliance claims fall outside workers’ comp exclusivity | School Board: some claims barred as work‑related; district court applied exclusivity to tort claims | Court of appeal had correctly held contract/detrimental reliance claims were not barred; Supreme Court does not disturb that outcome except to reverse bad‑faith damages |
Key Cases Cited
- Pizzolato v. State Through Bd. of Elementary and Secondary Educ., 452 So.2d 264 (La. App. 1 Cir. 1984) (tenure provisions read into employment contracts)
- Dorsett v. Johnson, 786 So.2d 897 (La. App. 2 Cir. 2001) (definition and standard for bad faith under art. 1997)
- Delaney v. Whitney Nat’l Bank, 703 So.2d 709 (La. App. 4 Cir. 1997) (bad‑faith principles in contract breach context)
- Adams v. First Nat’l Bank of Commerce, 644 So.2d 219 (La. App. 4 Cir. 1994) (bad faith requires more than negligence)
- Benton v. Clay, 123 So.3d 212 (La. App. 2 Cir. 2013) (conscious wrongdoing vs. bad judgment distinction)
- Bond v. Broadway, 607 So.2d 865 (La. App. 2 Cir. 1992) (cases discussing bad‑faith contractual breach)
- Weysham v. Harney, 518 So.2d 1059 (La. App. 4 Cir. 1987) (bad‑faith standard in contract performance)
- Castille v. St. Martin Parish School Bd., 190 So.3d 1225 (La. App. 3 Cir. 2016) (appellate decision finding breach and awarding bad‑faith damages)
- State ex rel. Nobles v. Bienville Parish School Bd., 4 So.2d 649 (La. 1941) (authority for tenure provisions being read into contracts)