Breaux v. Worrell
CourtCourt of Appeals for the Fifth Circuit
Date FiledSeptember 9, 2026
Docket24-30097
StatusPublished
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Full Opinion
Case: 24-30097 Document: 117-1 Page: 1 Date Filed: 09/09/2026
United States Court of Appeals
for the Fifth Circuit United States Court of Appeals
____________ Fifth Circuit
FILED
No. 24-30097 September 9, 2026
____________ Lyle W. Cayce
Clerk
Edward F. Breaux, Jr.; Linda Breaux,
Plaintiffs—Appellants,
versus
Kevin Ray Worrell; City of Wilson North Carolina;
Travelers Indemnity Company, incorrectly named as Travelers
Indemnity Insurance Company; Travelers Property
Casualty Company of America,
Defendants—Appellees,
______________________________
Jessie J. Blanchard; Vickie B. Blanchard,
Plaintiffs—Appellants,
versus
Travelers Indemnity Company; Kevin Ray Worrell, City of
Wilson North Carolina,
Defendants—Appellees.
______________________________
Appeal from the United States District Court
Case: 24-30097 Document: 117-1 Page: 2 Date Filed: 09/09/2026
for the Western District of Louisiana
USDC Nos. 6:22-CV-5169, 6:22-CV-5254
______________________________
Before Higginbotham, Willett, and Ho, Circuit Judges.
Patrick E. Higginbotham, Circuit Judge:
In January 2024, a federal district court granted summary judgment in
favor of the defendants, Kevin Worrell, the City of Wilson, North Carolina,
and the City’s insurers, holding that Worrell and the City of Wilson were
entitled to statutory immunity under Louisiana’s Homeland Security and
Emergency Assistance and Disaster Act (LHSEADA). The Breauxs and the
Blanchards appealed, challenging the district court’s interpretation of the
scope of the Act’s immunity provision.
On June 25, 2025, we certified two questions regarding the
interpretation of the Act’s immunity provision to the Supreme Court of
Louisiana:
(1) Is an employee of a city of another state—working under an
agreement for emergency assistance between that city and a
Louisiana municipality—a “representative” of the State of
Louisiana or one of its political subdivisions within the meaning
of La. R.S. 29[:]735?
(2) Is an individual providing emergency assistance in
Louisiana “engaging in . . . emergency preparedness and
recovery activities” under La. R.S. 29[:]735 while commuting
from the recovery site to his lodging? 1
On April 10, 2026, the Supreme Court of Louisiana issued its opinion
in response to our certified questions, holding that Worrell “would not be
considered to have been a ‘representative’ of any Louisiana governmental
_____________________
1
Breaux v. Worrell, 141 F.4th 712, 719 (5th Cir. 2025). The factual circumstances
and procedural history of this case are fully recounted in our published opinion certifying
the question. Id. at 714–15.
2
Case: 24-30097 Document: 117-1 Page: 3 Date Filed: 09/09/2026
No. 24-30097
entity . . . for purposes of LHSEADA immunity.” 2 As “that failure alone
disqualifies him for immunity under the statute[,]” the Supreme Court of
Louisiana declined to consider the second certified question. 3
In light of this decision by the Supreme Court of Louisiana, we
REVERSE the district court’s judgment and REMAND for further
proceedings consistent with this opinion.
_____________________
2
See Breaux v. Worrell, 431 So.3d 375, 383–84 (La. 2026).
3
Id. at 384.
3