James Bowie v. Knight Transportation, Inc. and Sedgwick

STATE OF LOUISIANA JAMES BOWIE NO. 2025 CW 0653 VERSUS KNIGHT TRANSPORTATION, INC OCTOBER 23, 2025 In Re: Knight Transportation, Inc. and Sedgwick, for applying supervisory writs, Office of Workers' Compensation, District 6, No. 24- 02798. BEFORE: McCLENDON, C. J., LANIER, GREENE, STROMBERG AND FIELDS, JJ. WRIT GRANTED. The Office of Workers' Compensation' s February 18, 2025 judgment which overruled Defendants', Knight Transportation, Inc. and Sedgwick, Exception of Lack of Subject Matter Jurisdiction is reversed. The determination as to whether a claimant was working under a contract of hire made in Louisiana, pursuant to La. R. S. 23: 1035. 1, is a factual one. Jackson v. Royal T Energy, LLC, 50, 645 ( La. App. 2d Cir. 6/ 22/ 16) , 197 So. 3d 706, 709 , writ denied, 2016- 1383 ( La. 11/ 7/ 16), 209 So. 3d 99 . The facts relevant to this inquiry are undisputed that plaintiff, James Bowie, travelled to Mississippi to complete pre- employment paperwork, drug testing, and a driving test, etc.; was dispatched to multiple states, including Louisiana, from Mississippi; and the conditional offer stated he was not hired the officially until pre- employment conditions had been met. These facts show that a contract of hire was not made in Louisiana under La. R. S. 23: 1035. 1. Therefore, Defendants' Exception of Lack of Subject Matter Jurisdiction is granted and plaintiff' s claims are dismissed without prejudice. WIL HG TPS WEF McClendon, C. J., dissents and would deny the writ. COURT OF APPEAL, FIRST CIRCUIT