LONDON v. JAMBALAYA CAPITAL (2025)

Writ granted. The court of appeal erred in holding that the Special Event Participant Exclusion was not applicable to the decedent's participation in a parade. Although the court of appeal relied on the fact that the definitions of the terms “demonstration,” “exhibition,” and “show” did not include or refer to “parade,” the definitions of those terms describe circumstances that most people would find equally applicable to a description of a parade. See Scottsdale Insurance Company v. Chinese Consolidated Benevolent Association, A112281, 2006 WL 3826685, at *3 (Cal. Ct. App. Dec. 29, 2006) (“The words ‘demonstration’ and ‘exhibition’ ․ would certainly be commonly understood to include a parade.”). Accordingly, the judgment of the court of appeal is reversed and the judgment of the district court, which granted summary judgment dismissing the third-party demand against Ategrity Insurance Company, is reinstated. We further decree that the dismissal is with prejudice.

I respectfully dissent from the majority's grant of summary judgment without the benefit of the full insurance contract. The full contract would have allowed this Court to review the terms in context, including its definition section. La. C.C. art. 2050. In the absence of the contract, I would not find that a “parade” and an “exhibition” are synonymous as a matter of law.¹

FOOTNOTES

1.   The majority cites an unpublished California appellate court opinion for the proposition that a “parade” and an “exhibition” are the same. However, given Louisiana's culture, our citizens would not view them as having the same meaning – we refer to “Mardi Gras parades,” not “Mardi Gras exhibitions.” La. C.C. art. 2047.

PER CURIAM.

Hughes, J., dissents for the reasons assigned by Griffin, J. Griffin, J., dissents and assigns reasons.