Trade-Winds Environmental Restoration, Inc. v. Stewart Development, LLC, 409 F. App'x 805

Stewart Development owned a Metairie building damaged by Hurricane Katrina.
Stirling Properties served as leasing manager and agent for the damaged building.
Trade-Winds signed a mold-remediation contract with Stewart on September 22, 2005.
Trade-Winds did not hold Louisiana licenses for general contracting or mold remediation at signing.
Trade-Winds obtained a mold-remediation license on February 16, 2006; work was claimed completed March 11, 2006.
In June 2006, Trade-Winds sued for breach; district court later held contract void and limited claims to unjust enrichment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the contract was null and void for lack of a license	Trade-Winds argued licenses relaxed temporarily post-Katrina could validate the contract.	Contract without required license is null and void under Louisiana law.	Contract void; license relaxation did not validate.
Whether the district court abused its discretion denying reconsideration on a new legal theory	Emergency-license reciprocity could apply to permit work without local license.	New theory raised late; district court properly denied reconsideration.	No abuse; rejection of new theory affirmed.

Hagberg v. John Bailey Contractor, 435 So. 2d 580 (La. App. 3 Cir. 1983) (license requirement renders contract void)
Alonzo v. Chifici, 526 So.2d 237 (La. App. 5 Cir. 1988) (contracting without license void; public policy)
Trade-Winds Envtl. Restoration, Inc. v. St. Tammany Park, 578 F.3d 255 (5th Cir. 2009) (license-law strict; post-disaster licensing relaxation not suspend requirement)
Bolton v. City of Dallas, 472 F.3d 261 (5th Cir. 2006) (summary judgment standards; de novo review)
Gasperini v. Center for Humanities, Inc., 518 U.S. 415 (U.S. 1996) (state-law interpretation reviewed de novo)
Salve Regina College v. Russell, 499 U.S. 225 (U.S. 1991) (uniform standard for state-law issues; no deference to state court on issues of law)