300 So.3d 12
La. Ct. App.2020Background
- In May 2014, 14-year-old Chayse Juneau suffered heat-related illness (acute rhabdomyolysis and renal failure) while playing in a USTA‑sanctioned Louisiana Junior Qualifier run by the Acadiana Community Tennis Association (ACTA).
- Chayse’s mother, Kelly Juneau, told the match referee (Marijane Jeansonne) to stop the match after observing Chayse’s disorientation; the referee allowed Chayse to continue after he said he was fine.
- Tournament staff and a medical trainer later treated Chayse; he was subsequently hospitalized and alleges lasting deficits from the heat injury.
- The ACTA organized and operated the event; the USTA’s only involvement was sanctioning the tournament and certifying that Jeansonne was a qualified referee; USTA personnel were not present or managing the event.
- Juneau sued USTA (and others). The trial court granted USTA’s motion for summary judgment dismissing claims against USTA; Juneau appealed and the court of appeal affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether USTA owed a duty to participant by sanctioning the tournament | USTA’s sanction and provision of rules created a duty to protect participants | Sanctioning only recognizes event for ranking; USTA had no operational control or presence and thus no duty | No duty: sanctioning alone did not impose a legal duty to the player |
| Whether USTA had a duty to train referees or adopt heat‑illness policies | USTA’s Friend at Court Manual and certification program imposed a duty to train referees to recognize/treat heat illness | USTA’s materials target tournament directors; USTA does not train referees on heat‑illness recognition and did not assume operational responsibility | No duty: USTA did not undertake or assume that specific training/policy role under these facts |
| Whether USTA is vicariously liable for referee’s conduct | Juneau argues referee was USTA‑certified so USTA should be liable | USTA argues referee was selected/paid by ACTA and was not USTA employee or agent for the event | No vicarious liability: referee was not USTA employee and ACTA controlled staffing |
| Whether expert opinions create a genuine issue of material fact on duty | Expert (Dr. Casa) opined failures by organizers and officials created safety lapses and criticized responses | USTA notes expert did not identify deficiencies in USTA’s manual or training and legal question of duty not resolved by expert opinion | Expert opinions insufficient to create a factual dispute on legal duty owed by USTA; summary judgment affirmed |
Key Cases Cited
- Moreno v. Entergy Corp., 105 So. 3d 40 (La. 2012) (standard of appellate review for summary judgment)
- Pontchartrain Natural Gas System v. Texas Brine Co., 281 So. 3d 1 (La. App. 1st Cir.) (duty‑risk negligence framework)
- Tate v. Outback Steakhouse of Florida, 203 So. 3d 1075 (La. App. 1st Cir.) (summary judgment: courts must not weigh evidence or assess credibility)
- Edwards v. Doug Ruedlinger, Inc., 669 So. 2d 541 (La. App. 4th Cir.) (no duty by statewide athletic association to control conduct at local games)
- Harvey v. Ouachita Parish School Bd., 545 So. 2d 1241 (La. App. 2d Cir.) (association that certifies officials not liable for referees hired by schools)
- Fecke v. Bd. of Supervisors of La. State Univ., 180 So. 3d 326 (La. App. 1st Cir.) (distinguishable: duty to train where employer‑employee relationship and direct control existed)
- McGowan v. Victory and Power Ministries, 757 So. 2d 912 (La. App. 1st Cir.) (undertaker liability: if one assumes a task, must perform it reasonably)
- Bowman v. City of Baton Rouge/Par. of East Baton Rouge, 849 So. 2d 622 (La. App. 1st Cir.) (expert opinion cannot by itself establish legal duty when factual/legal issues control)