THIBODEAUX, Chief Judge.
Plaintiff, Theodore Venissat, was rear-ended by a sheriff's deputy, Charles Ferguson, while stopped at a traffic light. Mr. Venissat and his wife sued the deputy and his employer, the Calcasieu Parish Sheriff's Department (CPSD), as well as the CPSD's liability insurer, St. Paul Fire & Marine Insurance (St. Paul), for damages sustained as a result of the collision.
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