Tyrone Saylor v. Villcar Realty, L.L.C. and Carter-Downing Apartments, Inc., 999 So.2d 61 (La. App. 4th Cir. 2008)

Tenant suffered personal injuries when, after a fire broke out in his apartment, he jumped from a second-story window. Tenant filed suit against the apartment complex owner, Villcar Realty, alleging negligence and breach of contract. The district court granted Villcar's exception of prescription, finding that tenant's action sounded in tort only and that the doctrine of contra non valentem did not apply. The Fourth Circuit affirmed the trial court's ruling, agreeing that the action was delictual and the evidence did not support application of contra non valentem.