Justia Louisiana Supreme Court Opinion Summaries

The dispute arose after the United States constructed navigation structures in the Catahoula Basin, raising water levels and affecting property in the area. Landowners in the basin, divided into Lake Plaintiffs and Swamp Plaintiffs, brought a class action against the State of Louisiana, alleging unlawful expropriation of their land and seeking damages, a declaration of ownership, and recovery of mineral royalties. The central factual issue was how to classify the Catahoula Basin: the Lake Plaintiffs argued it was part of the Little River’s banks, entitling them to ownership, while the State argued it was a lake owned by the state.After a bench trial in the Ninth Judicial District Court, the court found in favor of the plaintiffs, recognizing the Lake and Swamp Plaintiffs as owners of the disputed lands, awarding damages for inverse condemnation, and granting attorney fees. The Louisiana Court of Appeal, Third Circuit, affirmed most of the judgment but shifted the attorney fee burden entirely to the plaintiffs’ common fund. The Louisiana Supreme Court then held that plaintiffs’ compensation claims had prescribed, reversing the damages awards but leaving the attorney fee issue unresolved. When the trial court subsequently recalculated attorney fees using the lodestar method, the appellate court increased the award by applying a fourfold multiplier, finding the initial fee too low given the case’s complexity and duration.The Supreme Court of Louisiana reviewed the attorney fee award and found that while a multiplier was warranted due to the exceptional duration, risk, and complexity of the litigation, the appellate court’s fourfold multiplier was excessive given the high hourly rate used in the lodestar calculation. The court reduced the multiplier to three, setting the attorney fee at $16,713,656.20, and affirmed the appellate court’s judgment as amended. The matter was remanded for the trial court to determine appropriate reserves and payment arrangements. View "CROOKS VS. STATE" on Justia Law

The judges of the Municipal and Traffic Court of New Orleans determined that new technological demands required the addition of a court technology officer, a position to be directly managed by the judges. After receiving approval from the City’s Chief Administrative Office, the judges requested that this new role be designated as “unclassified” and placed on the city’s unclassified payroll system. The Personnel Director for the City referred the matter to the Civil Service Commission, which denied the request, reasoning that similar positions existed in the classified service. The judges subsequently filed a petition for writ of mandamus and declaratory judgment, seeking a court order to compel entry of the technology officer position onto the unclassified payroll and to declare that the Civil Service Commission had no authority over such appointments.The Civil District Court for the Parish of Orleans granted both the writ of mandamus and declaratory judgment in favor of the judges, finding that employees hired by the judges for the Municipal and Traffic Court were in the unclassified service under the Louisiana Constitution and that the Civil Service Commission lacked jurisdiction over the number or terms of such employees. On appeal, the Louisiana Court of Appeal, Fourth Circuit, reversed, holding for the Commission.The Supreme Court of Louisiana reviewed the case on writ of certiorari. The Court held that, under the Louisiana Constitution, employees of the Municipal and Traffic Court (other than those in the clerk’s office) are in the unclassified service, and the Civil Service Commission’s rulemaking authority does not extend to these unclassified positions. The Court determined that neither the Constitution nor the relevant statutes limit the number of unclassified employees the judges may appoint when acting collectively. As a result, the Supreme Court vacated the judgment of the Court of Appeal and reinstated the judgment of the trial court, granting relief to the judges. View "JONES VS. TREPAGNIER" on Justia Law

The dispute centers on ownership of a half-interest in a tract of land in DeSoto Parish, Louisiana, originally owned by Augustine Howard, who died intestate in 1956. A 1996 judgment of possession recognized Earnestine Walker as Augustine Howard’s sole heir, through whom Windward Land, LLC and Michael Morris Gulley claim title. Opposing parties, whose title traces back to Addie Edwards via a 1955 deed, argue that Earnestine Walker, as an illegitimate child, was precluded from inheriting under the law in effect at the time of Augustine’s death and that Zephyr Johnson, Augustine's niece, was the rightful heir.The Frazier-Edwards respondents sought a declaratory judgment to invalidate the 1996 judgment of possession, which the District Court granted, finding Zephyr Johnson the rightful heir and awarding sole ownership to the Frazier-Edwards group. Windward moved for a new trial, asserting that any attack on the 1996 judgment was barred by prescription under La. R.S. 9:5630, but the motion was denied. The Louisiana Court of Appeal, Second Circuit, affirmed, narrowly interpreting La. R.S. 9:5630 to bar only claims by heirs or legatees of the decedent, not claims by heirs or legatees of a third party transferee.The Supreme Court of Louisiana granted certiorari and held that the prescriptive bar in La. R.S. 9:5630 applies broadly, including to actions by buyers, donees, and transferees who acquire immovable property from heirs or legatees recognized in a judgment of possession. The Court concluded the Frazier-Edwards respondents’ collateral attack was prescribed and the 1996 judgment of possession remains valid. The rulings of the lower courts were vacated, and the matter remanded for further proceedings consistent with this opinion. View "WINDWARD LAND, LLC VS. MANN" on Justia Law

On June 3, 2020, officers responded to a home after Ms. Annie Grace and her daughter saw two individuals on surveillance footage, one carrying a gas can and pouring gasoline around the property. An officer discovered a burnt paper bag near the driveway, but no structural damage occurred. Following an anonymous tip, police interrogated a juvenile who implicated Mardeontae Lee as the individual pouring the gasoline. Lee admitted his involvement, explaining he acted out of fear for his life after being pressured by gang members, specifically Kadrick Thompson, who told him the plan was retaliation for a murder involving Ms. Grace’s son. Lee stated he did not intend to harm anyone, only to feign an attempt to placate threats against him.Lee was charged in the Twenty-Second Judicial District Court with aggravated arson and three counts of attempted first degree murder. A jury found him guilty on all counts. The Court of Appeal, First Circuit, affirmed the convictions, holding that the evidence was sufficient to support the verdicts.Upon review, the Supreme Court of Louisiana determined whether the evidence supported Lee’s convictions. The Court held that the statutory definition of "movable" for aggravated arson requires a facility or enclosure for fifty or more people, which was not present. The only responsive verdict was not guilty, so the conviction was reversed. For attempted first degree murder, the Court found the State’s circumstantial evidence did not exclude Lee’s reasonable hypothesis of innocence—namely, that he lacked specific intent to kill. Therefore, the convictions for attempted first degree murder were also reversed, and judgments of acquittal entered. The Supreme Court of Louisiana remanded the case to the trial court with instructions to discharge the defendant. View "STATE VS. LEE" on Justia Law

The defendant was convicted in 1998 of first degree murder and sentenced to death after the drowning death of a 23-month-old child in his care. The prosecution’s case rested on forensic evidence suggesting the child was violently assaulted, bitten, sexually abused, and forcibly drowned, while the defense argued for accidental drowning due to a seizure and challenged the forensic findings. The conviction was affirmed on direct appeal, and certiorari was denied.Following conviction, the defendant pursued post-conviction relief in Louisiana’s Fourth Judicial District Court, presenting new evidence that undermined the reliability of the forensic experts whose testimony was pivotal at trial. This included developments in bite mark analysis and pediatric pathology, expert opinions that the death was accidental, and evidence impeaching a jailhouse informant’s confession testimony. The trial court held a multi-day evidentiary hearing and found the new evidence, especially regarding the state’s forensic experts, was reliable, noncumulative, and would likely have led to acquittal. Relief was granted under La. C.Cr.P. art. 930.3(1) (ineffective assistance) and art. 930.3(8) (factual innocence), and the conviction and sentence were vacated.The Supreme Court of Louisiana reviewed the trial court’s ruling for abuse of discretion, as the state did not contest legal errors in the factual innocence analysis. Applying La. C.Cr.P. art. 926.2, the court held that the defendant had presented new, reliable, noncumulative evidence which, viewed with all relevant evidence, proved by clear and convincing evidence that no rational juror would have found guilt beyond a reasonable doubt. The judgment vacating the conviction and sentence was affirmed, and relief was granted under La. C.Cr.P. art. 930.3(8). View "STATE OF LOUISIANA VS. DUNCAN" on Justia Law

After Hurricane Ida and other storms struck Louisiana, thousands of residents hired a Houston-based law firm under contingent fee contracts to pursue damage claims. Concerns emerged regarding the firm’s handling of these cases, leading to disciplinary and sanction actions by multiple courts. The Louisiana Supreme Court suspended the firm’s lead attorney’s license and stayed the firm’s cases in state courts. Subsequently, the firm withdrew or was discharged from virtually all remaining cases, and successor law firms resolved many claims. The firm filed for bankruptcy and asserted claims against successor law firms for attorney fees and costs from settlements, sparking disputes over the validity of its contracts in light of alleged misconduct.The United States District Court for the Southern District of Texas, after a jury demand by a successor firm, withdrew the case from bankruptcy court and certified several questions to the Supreme Court of Louisiana. The parties agreed that Louisiana substantive law governs the fee dispute. No factual findings were made about the misconduct allegations; the federal court and Louisiana Supreme Court addressed questions hypothetically.The Supreme Court of Louisiana held that a contingent fee contract formed as a result of unethical or illegal conduct by an attorney is absolutely null, and the attorney cannot recover fees or costs, even on a quasi-contract or quantum meruit basis. If an attorney engages in misconduct after a valid contract is formed, recovery of fees and costs is governed by the Saucier v. Hayes Dairy Products, Inc. and O’Rourke v. Cairns framework, which allows for fee allocation based on the nature and gravity of the misconduct. The Court clarified that any person, including successor law firms, may assert absolute nullity of such contracts. The Court also declined to address procedural questions governed by federal law, such as whether a judge or jury should determine fee reductions in federal court. View "IN RE: MMA LAW FIRM, PLLC" on Justia Law

A juvenile in Orleans Parish was arrested and evidence was seized pursuant to warrants issued by a juvenile court hearing officer, rather than a judge or magistrate. The authority for the hearing officer to issue arrest and search warrants stemmed from local court rules adopted by the Orleans Parish Juvenile Court. The defendant challenged the validity of both the arrest and the search, arguing that the local rules conflicted with Louisiana statutes and the state constitution, which reserve warrant-issuing authority to judges and magistrates unless otherwise expressly permitted by law.The Criminal District Court for the Parish of Orleans denied the defendant’s motion to suppress the evidence obtained through the search and arrest warrants. The court held that the hearing officer acted with apparent authority under the court’s local rules, and that the warrants were valid at the time they were issued.Upon review, the Supreme Court of Louisiana addressed whether the local rules authorizing hearing officers to issue arrest and search warrants were valid under Louisiana law, and whether warrants already issued under those rules should be invalidated. The court held that the relevant provisions of the local rules conflicted with the Louisiana Children’s Code, the Louisiana Code of Criminal Procedure, and the Louisiana Constitution, and were therefore null and void. However, applying the de facto officer doctrine, the court found that the hearing officer’s acts were valid because the officer acted under color of authority before the rules were judicially declared invalid. Accordingly, the Supreme Court of Louisiana affirmed the trial court’s denial of the motion to suppress and remanded the case for further proceedings. View "STATE OF LOUISIANA VS. OWNEY" on Justia Law

Curtis Lee Stewart, Jr. was indicted for second degree murder following the April 25, 2021 fatal shooting of Devonta Ennis in Baton Rouge, Louisiana. Surveillance video showed two vehicles, a white Chevrolet Traverse and a silver Nissan Armada, boxing in Mr. Ennis’s car before an occupant of the Traverse opened fire. Both vehicles were later found burned nearby; each was registered or leased to women romantically linked to Stewart. Cell phone records showed Stewart’s phone moving between the locations of the vehicle theft and the murder scene at relevant times. Testimony and recorded interviews indicated Stewart took one of the vehicles and later instructed witnesses not to cooperate with authorities.After a bench trial in the Nineteenth Judicial District Court, Stewart was found guilty and sentenced to life imprisonment without parole. The trial court’s per curiam noted that circumstantial evidence excluded every reasonable hypothesis of innocence. Stewart appealed. The Louisiana Court of Appeal, First Circuit, reversed the conviction, determining that the evidence failed to establish Stewart’s identity as the shooter and that the trial court’s conclusion was based on speculation. The appellate court emphasized the absence of physical evidence or witness identification directly linking Stewart to the shooting and found the State had not negated the possibility of misidentification.The Supreme Court of Louisiana reviewed the case, applying the Jackson v. Virginia standard, which requires the evidence to be viewed in the light most favorable to the prosecution. The Court found that the evidence, including Stewart’s involvement with the vehicles, his cell phone activity, witness tampering, and specific intent inferred from the circumstances, was sufficient for a rational trier of fact to convict Stewart as a principal to second degree murder, even absent direct evidence he fired the fatal shots. Accordingly, the Supreme Court of Louisiana reversed the appellate court’s judgment and reinstated Stewart’s conviction and sentence. View "STATE OF LOUISIANA VS. STEWART" on Justia Law

The case centers on an employee who was involved in a workplace motor vehicle accident. Initially, the employer did not pay any workers’ compensation benefits. The employee, after reporting neck and back injuries through counsel, filed a claim for compensation. During a deposition, the employee claimed he had received emergency room treatment for his injuries two days after the accident, but medical records contradicted this. The employer asserted that this was a willful misrepresentation made to obtain workers’ compensation benefits.The Office of Workers’ Compensation, District 6, reviewed the claim. The workers’ compensation judge found the employee to be temporarily totally disabled for a period prior to the deposition and awarded indemnity and medical benefits for that period. However, the judge also found the employee had willfully made false statements in his deposition, resulting in a forfeiture of his right to benefits from the date of the deposition forward and assessed a civil penalty. The employer appealed, seeking retroactive forfeiture from the date of the accident, and the employee argued his statements were not willful misrepresentations. The Court of Appeal, First Circuit, upheld the prospective forfeiture, relying on its precedent, and partially modified the attorney’s fee award.The Supreme Court of Louisiana reviewed the case to resolve a circuit split regarding the timing of forfeiture under Louisiana Revised Statute 23:1208. The Court held that forfeiture of workers’ compensation benefits for willful misrepresentation is prospective only, commencing from the date of the misrepresentation, not retroactive to the date of the accident. The Court affirmed the judgment of the appellate court and overruled contrary precedent to the extent it held forfeiture was retroactive. View "COUSAIN VS. SMITTY'S SUPPLY, INC." on Justia Law

Orleans Parish historically maintained separate clerks of court for its Civil District Court and Criminal District Court. In November 2025, Chelsey Richard Napoleon was reelected as clerk of the Civil District Court, and Calvin Duncan was elected as clerk of the Criminal District Court, with both terms set to begin in May 2026. On April 30, 2026, Act 15 was signed into law, immediately abolishing the office of clerk of the Criminal District Court as of May 3, 2026, and transferring all its duties and property to the civil clerk, who would thereafter be known as the clerk of court for Orleans Parish.Following this enactment, Gary Crockett, a voter, filed suit in the 19th Judicial District Court, arguing that abolishing the criminal clerk’s office required a constitutional amendment. The district court issued an injunction halting the consolidation of the clerk’s offices. Meanwhile, the New Orleans City Council declared a vacancy in the clerk’s office and appointed an interim clerk, which led Ms. Napoleon to bring a separate suit challenging the City’s actions. The Supreme Court of Louisiana then assumed jurisdiction over both cases, stayed lower court proceedings, and enjoined interference with Ms. Napoleon’s duties under Act 15.The Supreme Court of Louisiana held that Act 15 was a constitutional and valid exercise of legislative power under La. Const. Art. V, § 32, which allows the legislature to restructure or abolish specified Orleans Parish court offices by law. The Court found that Act 15 did not create a vacancy but merely transferred duties as permitted. It reversed the district court’s injunction, declared Act 15 effective, made its own injunction permanent, and enjoined any further attempts to appoint an interim clerk or call a special election. The stay of proceedings was lifted. View "CROCKETT VS. STATE OF LOUISIANA" on Justia Law