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March 3, 2026 Get Citation Alerts Download PDF Add Note

Brett Lirette v. Jason C. Adams, State Farm Mutual Automobile Insurance Company, Geico Casualty Company, & Axis Ventures, LLC

Louisiana Court of Appeal

• Citations: None known
• Docket Number: 2025-CA-0650
• Judges: Judge Joy Cossich Lobrano; Judge Tiffany Gautier Chase; Judge Monique G. Morial

• Disposition: Appeals Dismissed Lobrano, J., Concurs in the Result

• Opinion

• Authorities (5)

• Cited By (0)

• Summaries (0)

• Similar Cases (21.7K)

• PDF

Disposition

Appeals Dismissed Lobrano, J., Concurs in the Result

Lead Opinion

                        by Judge Monique G. Morial

BRETT LIRETTE * NO. 2025-CA-0650

VERSUS *
COURT OF APPEAL
JASON C. ADAMS, STATE *
FARM MUTUAL FOURTH CIRCUIT
AUTOMOBILE INSURANCE *
COMPANY, GEICO STATE OF LOUISIANA
CASUALTY COMPANY, & *******
AXIS VENTURES, LLC

CONSOLIDATED WITH: CONSOLIDATED WITH:

BRETT LIRETTE NO. 2025-CA-0651

VERSUS

JASON C. ADAMS, STATE FARM
MUTUAL AUTOMOBILE INSURANCE
COMPANY, GEICO CASUALTY
COMPANY, & AXIS VENTURES, LLC
CONSOLIDATED WITH: CONSOLIDATED WITH:

BRETT LIRETTE NO. 2025-CA-0708

VERSUS

JASON C. ADAMS, ET AL
CONSOLIDATED WITH: CONSOLIDATED WITH:

BRETT LIRETTE NO. 2025-CA-0710

VERSUS

JASON C. ADAMS, STATE FARM
MUTUAL AUTOMOBILE INSURANCE
COMPANY, GEICO CASUALTY
COMPANY & AXIS VENTURES, LLC

APPEAL FROM
CIVIL DISTRICT COURT, ORLEANS PARISH
NO. 2016-05383, DIVISION “N-8”
Honorable Ethel Simms Julien

---

Judge Monique G. Morial

---

(Court composed of Judge Joy Cossich Lobrano, Judge Tiffany Gautier Chase,
Judge Monique G. Morial)

LOBRANO, J., CONCURS IN THE RESULT
Steven A. DeBosier
James Hilton Peltier, Jr.
Adras Paul LaBorde III
DUDLEY DEBOSIER INJURY LAWYERS
1075 Government Street
Baton Rouge, LA 70802

COUNSEL FOR PLAINTIFF/APPELLEE

Joseph M. Messina
Bradley S. Groce
LOBMAN CARNAHAN BATT ANGELLE & NADER
400 Poydras Street
Suite 2300
New Orleans, LA 70130

COUNSEL FOR DEFENDANT/APPELLEE

Kevin C. O'Bryon
Marta-Ann Schnabel
O'BRYON & SCHNABEL, PLC
935 Gravier Street
Suite 900
New Orleans, LA 70112

COUNSEL FOR DEFENDANT/APPELLANT

APPEALS DISMISSED
MARCH 3, 2026
This is a civil action arising out of a motor vehicle accident with a
MGM
complicated procedural history. The appeals at issue concern the district court’s
TGC
determination, on remand from this Court, that a policy issued by Defendant,

Geico Casualty Insurance Company (“GEICO”), provided coverage for the

accident at issue, as well as the district court’s granting of a JNOV which reduced

the jury verdict awards rendered against Defendant-driver Jason C. Adams (“Mr.

Adams”). As discussed more fully below, upon review of this matter, we find that

this Court lacks jurisdiction to consider the merits of the appeals. We accordingly

dismiss the appeals and remand this matter to the district court for further

proceedings consistent with this opinion.

FACTUAL AND PROCEDURAL BACKGROUND

The underlying factual and procedural background was provided by this

Court in our prior opinion, Lirette v. Adams, 2023-0527 (La. App. 4 Cir. 7/10/24),

399 So.3d 468, 474–75 (“Lirette II”):

“On May 4, 2016, Kristi Lirette was a passenger in a [black] 2015
Lamborghini Huracan driven by Mr. Adams.” “The vehicle collided

1
with a flood wall on Tchoupitoulas Street in New Orleans, and Kristi
Lirette died from the injuries she sustained in the accident.” Id. At the
time of the subject accident, Mr. Adams and his business partner, Dr.
Alireza Sadeghi (“Dr. Sadeghi”), each leased a [black] 2015
Lamborghini Huracan [together] with their business, Axis Ventures,
LLC (“Axis”). “Only after the accident did Mr. Adams realize that he
was inadvertently driving the vehicle leased to Dr. Sadeghi and Axis
(“Lamborghini [A]”), and not the vehicle leased to him and Axis
(“Lamborghini [B]”).”

Mr. Lirette filed a petition for damages on May 27, 2016, in which he
named Mr. Adams, GEICO Casualty Company (“GEICO”), State
Farm, and Axis as defendants. Germane to our review, “Mr. Lirette
alleged, in pertinent part, that an insurance policy issued by GEICO
(“GEICO Policy”) was in full force and effect at the time of the
subject accident and rendered GEICO jointly and solidarily liable for
the damages caused by Mr. Adams.” “Additionally, Mr. Lirette
[alleged] that two insurance policies issued by State Farm were in full
force and effect at the time of the subject accident and rendered State
Farm jointly and solidarily liable for the damages caused by Mr.
Adams.” These two policies were: State Farm Policy Number 286-
8850-F23-18A (“State Farm Policy A”), with named insureds Dr.
Sadeghi and Axis for the use of Lamborghini A; and State Farm
Policy Number 282-7788-D17-18B (“State Farm Policy B”), with
named insureds Mr. Adams and Axis for the use of Lamborghini B.

After answering the petition and conducting some limited discovery,
State Farm filed a motion for summary judgment on October 26,
2017, seeking to be dismissed as liability insurer for Mr. Adams’
collision under State Farm Policy B. Shortly thereafter, on November
16, 2017, GEICO filed its own motion for summary judgment,
arguing that, while it did have a policy affording coverage to Mr.
Adams at the time of the collision, that policy was for two of Mr.
Adams’ personal vehicles—a 2015 Chevy Tahoe and a 2016 Land
Rover/Range Rover—and that Lamborghini A did not qualify as a
“non-owned auto” or a “temporary substitute auto” under the GEICO
policy; thus, no coverage was provided to Mr. Adams under that
policy for the collision involving Lamborghini A.

---

Another hearing was conducted for these and several other pending
motions on April 1, 2022. The district court issued its judgment on
June 16, 2022, in which all of the Parents’ claims against GEICO
were dismissed with prejudice. In the same judgment, the district
court also dismissed with prejudice any of the Parents’ claims
pertaining to State Farm's liability for Mr. Adams’ accident under

2
State Farm Policy B. State Farm conceded that there was coverage for
the accident under State Farm Policy A.

Separately, both Mr. Adams and the Parents devolutively appealed the
June 16, 2022 judgment to this Court, which was the subject of Lirette
I [Lirette v. Adams, 22-0552 (La. App. 4 Cir. 1/31/23), 382 So.3d
122 ]. We then granted GEICO’s unopposed motion to consolidate the
two appeals, but explained that because of the dissimilar procedural
posture of the issues presented, we would review them
separately. After review, we found that the portion of the judgment
dismissing with prejudice State Farm’s liability under Policy B was
interlocutory and non-appealable because it did not dismiss all claims
against State Farm that were still pending related to Policy A. More
notably, we determined that there was a genuine issue of material fact
whether Lamborghini A did, in fact, qualify as a “non-owned auto”
under the terms of the GEICO policy. As a result, we reversed the
portion of the district court’s June 16, 2022 judgment that granted
GEICO’s motion for summary judgment and dismissed the Parents’
claims against GEICO with prejudice, and remanded the matter back
to the district court. We published our opinion in Lirette I on January
31, 2023.

Precisely three months earlier, the Parents’ suit for damages came for
jury trial on October 31, 2022, and concluded on November 7, 2022,
with a jury verdict in favor of the Parents and against Mr. Adams and
State Farm. Because GEICO had been dismissed as a defendant in the
June 16, 2022 judgment, it made only a limited appearance and did
not meaningfully participate in the trial.5 The district court adopted the
jury's liability findings and damage awards in its February 27, 2023
judgment, which cast Mr. Adams in judgment for the following
amounts:

(1) $12,000,000.00 in wrongful death damages to Brett Lirette;
(2) $12,000,000.00 in wrongful death damages to Diana King;
(3) $2,000,000.00 in survival damages of Kristi Lirette; and
(4) $25,000,000.00 in punitive damages against Mr. Adams.

Additionally, State Farm was cast in judgment for $250,000.00—the
limits of its coverage provided under State Farm Policy A. On March
8, 2023, Mr. Adams filed a Motion for Judgment Notwithstanding the
Verdict, Remittitur, or in the alternative, Motion for New Trial
(“motion for JNOV and motion for new trial”) which, after a hearing
on April 28, 2023, the district court denied.

Lirette v. Adams, 23-0527, pp. 2-5 (La. App. 4 Cir. 7/10/24), 399 So.3d 468, 474–
476 (footnotes omitted) (citations omitted).

3
In that appeal, Lirette II, this Court determined that the district court judge

legally erred when she opined that the jury damages awarded were unreasonably

high but nevertheless subsequently denied the JNOV. This Court reversed the

district court’s denial of the JNOV, and remanded the matter to the district court to

make an independent assessment of the damages awarded.

On remand, the district court, pursuant to this Court’s instructions in Lirette

II, (1) considered and granted the JNOV and (2) proceeded to a bench trial on the

issue of whether GEICO provided coverage for the accident at issue. On April 29,

2025, the district court issued a written judgment. The April 29, 2025 judgment

granted the JNOV, finding the original jury awards to be “excessively high,” and

reduced the awards for the wrongful death damages awarded to each parent as well

as the survival damages and punitive damages awarded.1

Concerning Plaintiffs’ claims against GEICO, the April 29, 2025 judgment

found that “the automobile liability insurance policy issued by Defendant, GEICO

Casualty Company, to Defendant, Jason C. Adams, provides liability insurance

coverage to Defendant, Jason C. Adams, for the May 4, 2016, crash and resulting

damages” subject to its “liability insurance limits of $250,000.00.” That April 29,

2025 judgment further awarded court costs against GEICO and “pre-judgment

judicial interest from date of judicial demand (May 27, 2016) until date of trial

Judgment (February 27, 2023) on the amount of $250,000.00, which amount of

pre-judgment judicial interest totals $78,565.80 and post[-]judgment judicial

interest from date of trial Judgment (February 27, 2023) on the amount of
1 The April 29, 2025 judgment reduced the jury verdict awards as follows:

(1) $12,000,000.00 in wrongful death damages to Brett Lirette reduced to $5,000,000.00;
(2) $12,000,000.00 in wrongful death damages to Diana King reduced to $5,000,000.00;
(3) $2,000,000.00 in survival damages of Kristi Lirette reduced to $1,000,000.00; and
(4) $25,000,000.00 in punitive damages against Mr. Adams reduced to $5,000,000.00.

4
$15,750,000.00 to April 21, 2025, which amount of post[-]judgment judicial

interest totals $2,637,154.11 and for post[-]judgment judicial interest after April

21, 2025, on the amount of $15,750,000.00 accruing at a daily rate of $3,559.93

(subject to increase of the judicial interest rate).”

On May 8, 2025, GEICO filed a motion for new trial as to the April 29, 2025

judgment, challenging the finding that GEICO’s policy provided coverage for the

accident at issue and further challenging the calculation or amount of pre and post

judgment judicial interest awarded in the April 29, 2025 judgment. Plaintiffs

opposed the motion for new trial, which the district court set for a June 11, 2025

hearing.

On July 8, 2025, the district court issued a written judgment stating only the

following: (1) “IT IS ORDERED, ADJUDGED AND DECREED that the

Lamborghini was not furnished for Mr. Adams ‘regular use, but was used at

random and sporadic times which would allow for coverage under the ‘non-owned

auto’ GEICO policy’ ” and (2) “IT IS FURTHER ORDERED, ADJUDGED

AND DECREED that the judicial interest under the GEICO policy limits of

liability runs from the date of judicial demand until paid or the money is deposited

into the registry of the court.”

The July 8, 2025 judgment did not grant or reference the filing of a motion

for new trial. Further, the July 8, 2025 judgment did not vacate the original April

29, 2025 judgment or reference any amendment to the April 29, 2025 judgment.

GEICO timely filed a motion and order for appeal from the April 29, 2025 and

July 8, 2025 judgements, which the district court granted on August 11, 2025.2

2 Defendant Mr. Adams also filed a motion for appeal, which the district court granted on

September 12, 2025.

5
On August 12, 2025, after the signing of the order of appeal and the posting

of the appeal bond, GEICO filed a “motion to amend” the July 8, 2025 and April

29, 2025 judgments to modify and combine both judgments into one final

judgment to reflect decretal language disposing of both GEICO’s liability

following trial, as well as the district court’s ruling on remand of the JNOV

reducing the jury verdict awards.

On October 30, 2025, the district court judge executed an “Amended Final

Judgment” substantively modifying, combining, and amending the previous April

29, 2025 and July 8, 2025 judgments.3

Jurisdictional Issue

“Prior to addressing the merits of an appeal, appellate courts have the duty to

determine sua sponte whether their appellate court jurisdiction has been properly

invoked by a valid, final judgment.” May v. Cooper/T. Smith Stevedoring Co., Inc.,

2024-0272, p. 3 (La. App. 4 Cir. 6/11/25), 421 So.3d 211, 214, writ denied, 2025-

00884 (La. 10/14/25), 418 So.3d 903, and writ denied, 2025-00886 (La. 10/14/25),

418 So.3d 904 (citing Safford v. New Orleans Fire Dept., 2023-0495, p. 18 (La.

App. 4 Cir. 2/1/24), 384 So.3d 909, 924-25 ). This Court cannot consider the

merits of an appeal unless and until our jurisdiction is properly invoked by a valid,

final judgment. Urquhart v. Spencer, 2015-1354, p. 3 (La. App. 4 Cir. 12/1/16),

204 So.3d 1074, 1077. “For a judgment to be a ‘valid final judgment,’ it must

contain specific ‘decretal language.’ ” Id. (citing Bd. of Supervisors of Louisiana

State Univ. v. Mid City Holdings, L.L.C., 2014–0506, p. 2 (La. App. 4 Cir.

10/15/14), 151 So.3d 908, 910). Moreover, “ ‘[t]he specific relief granted should

3There does not appear to be a motion and order for appeal related to the October 30, 2025

judgment.

6
be determinable from the judgment without reference to an extrinsic source such as

pleadings or reasons for judgment.’ ” Id. (quoting Input/Output Marine Sys., Inc. v.

Wilson Greatbatch, Tech., Inc., 2010–477, pp. 12–13 (La. App. 5 Cir. 10/29/10),

52 So.3d 909, 915–16).

“ ‘A valid judgment must be precise, definite and certain. ... The decree

alone indicates the decision. ... The result decreed must be spelled out in lucid,

unmistakable language. ... The quality of definiteness is essential to a proper

judgment.’ ” Urquhart v. Spencer, 2015-1354, p. 3, 204 So.3d at 1077 (quoting

Input/Output Marine Sys., Inc. v. Wilson Greatbatch, Tech., Inc., 2010–477, pp.

12–13, 52 So.3d at 915–16). In the absence of the necessary decretal language, the

judgment is not final and appealable. Id (citing Tsegaye v. City of New Orleans,

2015–0676, p. 3 (La. App. 4 Cir. 12/18/15), 183 So.3d 705, 710.

Moreover, La. C.C.P. art. 2088 provides that “[t]he jurisdiction of the trial

court over all matters in the case reviewable under the appeal is divested, and that

of the appellate court attaches, on the granting of the order of appeal and the timely

filing of the appeal bond, in the case of a suspensive appeal, or on the granting of

the order of appeal, in the case of a devolutive appeal.” “Once a judgment becomes

final and definitive and acquires the authority of the thing adjudged, no court has

jurisdiction, in the sense of power and authority, to modify, revise or reverse the

judgment, regardless of the magnitude of the error in the final judgment.” Abbott,

Price, Benjamin & Rue LLC v. Kodiak Partners LLC, 2025-0183, p. 4 (La. App. 4

Cir. 8/21/25), 419 So.3d 829, 832 (quoting Alonso v. Admin. Patient’s Comp.

Fund, 2020-211, p. 6 (La. App. 5 Cir. 12/30/20), 310 So.3d 297, 302).

Upon the granting of a motion for a suspensive appeal and the posting of the

appeal bond, the trial court is divested of jurisdiction, with limited exceptions.

7
Dailey v. The Home Furnishings Store, 2002-1225, p. 5 (La. App. 4 Cir. 9/17/03),

857 So.2d 1051, 1054-55. After the granting of an appeal, jurisdiction over the

issues on appeal lies with the appellate court and “every action taken and the

judgments rendered by the trial court” thereafter are nullities. Id.

First, as to the “Amended Final Judgment” issued on October 30, 2025,

more than two months after the granting of the order of appeal and posting of the

appeal bond, we find the district court lacked jurisdiction to execute that judgment.

Accordingly, the October 30, 2025 judgment is an absolute nullity.

Then, we are left to review the April 29, 2025 and July 8, 2025 judgments.

As to those judgments, we find this Court lacks jurisdiction to consider the appeals

of those judgments as they lack the required definitive and decretal language to

invoke our appellate jurisdiction. The July 8, 2025 judgment presumably granted

GEICO’s motion for new trial on the issue of judicial interest; however, the

judgment does not explicitly grant the motion for new trial. Importantly, the July 8,

2025 judgment is in direct conflict with the April 29, 2025 judgment. The July 8,

2025 judgment however did not vacate the prior April 29, 2025 judgment or state

that it modified the judgment in any way. In other words, this Court is faced with

two separate, inconsistent judgements that lack decretal and definitive language.

Therefore, we find that there is no valid and final judgment before the Court for

appellate review.

DECREE

Accordingly, we dismiss the appeals and remand this matter to the district

court for the amendment or issuance of a definitive, clear, final judgment, that the

parties may subsequently appeal.

APPEALS DISMISSED

8