State v. Placke - 34464 ( La. App. 2 Cir 05/09/01), 786 So. 2d 889

Rule:

A juridical person such as the State of Louisiana is incapable of forming the conscious moral feeling required to have a natural obligation.

Facts:

Appellants were plaintiffs and attorneys in a medical malpractice action in which actual damages against the State of over $ 3 million had been reduced to $ 500,000, plus interest, pursuant to a statutory limitation on the State's liability. Due to a clerical error, the State overpaid the amount due by $ 700,000. Appellants argued that the overpayment was payment of a natural obligation under La. Civ. Code art. 1760, 1761, and 1762, and did not have to be returned. The trial court granted summary judgment for the State. Appellants challenged the grant of summary judgment.

Issue:

Was the State’s overpayment a payment of a natural obligation under La. Civ. Code art. 1760, 1761, and 1762, and did not have to be returned? 

Answer:

No.

Conclusion:

The appellate court held that a juridical person such as the State could not form the conscious moral feeling required to have a natural obligation. Even if that were not the case, the fact that the State had capped its liability by statute showed that it had no intent to have any moral duty to pay any judgment in excess of the cap. Appellants could not prevail on the theory that a party who paid a natural obligation could not reclaim it once paid, as there was no obligation to pay in the first place. Appellants made their arguments in good faith however and the State could not claim pre-judgment interest.