Rachel Breaux v. Louisiana Stadium & Exposition District, Smg, Landmark Event Staffing Services, Inc., and Jane Doe, 390 So.3d 293

Rachel Breaux filed for Chapter 13 bankruptcy in 2012 and was required, as part of her plan, to disclose any pending or potential lawsuits to the bankruptcy trustee.
While the bankruptcy case was open, Breaux was allegedly injured, leading to litigation against several parties, including SMG and Jameika Gleason.
Breaux failed to disclose this personal injury claim (and two additional lawsuits) to the bankruptcy court as required by court order.
After discovery, defendants SMG and Gleason filed an exception of no right of action, arguing Breaux was judicially estopped from pursuing the lawsuit due to her failure to disclose during bankruptcy.
The trial court denied defendants' exception, holding Breaux was not judicially estopped and allowing her claim to proceed.
Defendants sought supervisory review with the Court of Appeal, which reversed the trial court, finding all elements of judicial estoppel met.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Breaux is judicially estopped from pursuing her claim due to failure to disclose it in bankruptcy	Breaux asserted she did not knowingly or intentionally fail to disclose, claiming lack of knowledge of her disclosure duty	Defendants argued Breaux had a duty to disclose all lawsuits and failed to do so, justifying judicial estoppel	Court held Breaux is judicially estopped; claim barred

Reed v. City of Arlington, 650 F.3d 571 (5th Cir. 2011) (outlines the three-part test for judicial estoppel in bankruptcy nondisclosure cases)
Webb v. Webb, 263 So. 3d 321 (La. 2018) (defines judicial estoppel and its equitable purpose)
Miller v. Conagra, Inc., 991 So. 2d 445 (La. 2008) (describes when nondisclosure is ‘inadvertent’ for judicial estoppel)