Justia Louisiana Supreme Court Opinion Summaries

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

The dispute centers on land in Calcasieu Parish, Louisiana, owned by a public entity, where oil and gas exploration occurred for decades under a mineral lease originally granted in 1943. The plaintiff acquired several tracts of this land between 1968 and 1987, with prior owners reserving mineral rights. The mineral lease was assigned multiple times before terminating in 2020. The plaintiff alleged that the defendants, or their predecessors, caused environmental damage to the property through oil and gas operations predating the plaintiff’s ownership, and sought damages under both tort and contract theories.Defendants filed exceptions of no right of action, arguing that under the “subsequent purchaser rule” articulated in Eagle Pipe and Supply, Inc. v. Amerada Hess Corp., a property owner cannot recover for damage inflicted before their purchase unless assigned the prior owner’s rights. The trial court denied these exceptions. On appeal, the Louisiana Court of Appeal, Third Circuit, reversed in part. It dismissed all claims against one defendant (Honeywell) for preacquisition damage, and limited claims against the other (Texas Pacific) to an 87-day period when both the plaintiff and Texas Pacific’s predecessor simultaneously held interests in one tract.The Supreme Court of Louisiana granted review. It extended the subsequent purchaser rule from Eagle Pipe to cases involving mineral leases, holding that a purchaser of property, absent an assignment or subrogation, has no right of action for preacquisition property damage caused by mineral lessees. However, the court recognized an exception for damages occurring during the period when the plaintiff owned the property and the defendant held lease rights. Additionally, the court held that a current surface owner may enforce the prudent operator standard under Mineral Code article 122 for end-of-lease obligations that become due upon termination, but not for historic operational damage. The judgment was affirmed in part, reversed in part, and remanded. View "VINTON HARBOR & TERMINAL DISTRICT VS. REUNION ENERGY COMPANY" on Justia Law

Two brothers were affiliated with a group engaged in ongoing gun violence with a rival group in Abbeville, Louisiana. About a year and a half after two shooting incidents involving one brother, a drive-by shooting occurred in a parking lot, resulting in the death of Jazaylon Levy. Video surveillance, witness testimony, vehicle measurements, and forensic evidence linked the brothers to a silver Mercedes-Benz seen at the scene and leaving shortly after the shooting. The evidence suggested the brothers intended to target a rival group associate and that one acted as the driver while the other fired the shots, causing Levy’s death.The case was tried in the District Court for the Parish of Vermilion, where a unanimous jury convicted both brothers of second degree murder. The trial judge imposed life sentences at hard labor without benefit of parole, probation, or suspension of sentence. After post-verdict motions were denied, the defendants appealed to the Louisiana Court of Appeal, Third Circuit. That court reversed the convictions, finding the evidence insufficient, particularly because the State had not excluded every reasonable hypothesis of innocence and misidentification, and the jury’s verdict was based on speculation.The Supreme Court of Louisiana reviewed the case on writ of certiorari. Applying the Jackson v. Virginia standard, the court held that, viewing the evidence in the light most favorable to the prosecution, a rational trier of fact could have found the defendants guilty beyond a reasonable doubt, and that the State had excluded every reasonable hypothesis of innocence. The court found the appellate court erred by substituting its judgment for the jury’s and reinstated the convictions and sentences, remanding the case to the appellate court to consider the defendants’ remaining assignments of error. View "STATE OF LOUISIANA VS. BRIGGS" on Justia Law

A married couple, Richard and Penny, entered into a separate property regime through an antenuptial agreement. Richard had two sons from a prior marriage. Upon his death, his son Bruce was named executor, and Penny was granted a usufruct over certain properties and a share in a partnership interest. After Richard’s death, Bruce, as executor, sought reimbursement from Penny for (1) Richard’s funds used to purchase a townhouse where both were listed as co-owners, (2) costs of improvements made to the townhouse, (3) a $1,000,000 check Richard gave Penny shortly before his death that she deposited into her separate account, and (4) a tax overpayment made by Richard that Penny used to pay her tax liabilities.The Twenty-Fourth Judicial District Court for the Parish of Jefferson denied most of Bruce’s reimbursement claims, finding that the Civil Code did not authorize reimbursement for the initial property purchase price and that Bruce had not met his burden to prove the value of improvements. The Louisiana Court of Appeal, Fifth Circuit affirmed. Bruce then sought review in the Supreme Court of Louisiana.The Supreme Court of Louisiana reversed in part and affirmed in part. The Court held that, although Richard and Penny were equal co-owners for title purposes, Bruce was entitled to claim reimbursement for Richard’s initial purchase price contribution to the townhouse because the Civil Code does not prohibit such reimbursement and principles of equity prevent unjust enrichment. The Court also ruled that the estate was entitled to reimbursement for the $1,000,000 check, finding Penny failed to prove donative intent by clear and convincing evidence, and for the tax overpayment, since it was paid solely from Richard’s funds. The Court affirmed the denial of reimbursement for alleged improvements, finding no manifest error in the lower courts’ factual determination that Bruce had not sufficiently proved the value of improvements. The matter was remanded for further proceedings. View "O'KREPKI VS. O'KREPKI" on Justia Law

A garbage truck driver was injured when his vehicle was struck by a train at a railroad crossing in Baldwin, Louisiana. The collision occurred after the left front tire of the garbage truck became stuck in a hole next to the wooden planks of the railroad crossing, which was maintained by the railroad company. The driver was delayed in maneuvering his truck out of the hole and, as he attempted to cross, was hit by an oncoming train. Evidence showed that the crossing was narrower than the adjacent roadway and did not meet industry or the railroad company's own safety standards.A jury in the 16th Judicial District Court found the railroad company negligent and a proximate cause of the accident, and also found the driver negligent but determined his negligence was not a proximate cause, yet assigned him 15% of the fault and the railroad 85%. The trial court entered judgment on this verdict. On appeal, the Louisiana Court of Appeal, First Circuit, found the jury's verdict inconsistent and ordered a new trial. The Louisiana Supreme Court vacated that order, holding that the driver’s acceptance of partial fault resolved the inconsistency, and remanded for review of other issues. On remand, the appellate court found the evidence supported the jury’s findings and damages award.The Supreme Court of Louisiana subsequently granted review to consider the allocation of fault. The court found manifest error in the jury’s allocation of 85% fault to the railroad and 15% to the driver. It held that the lowest reasonable allocation of fault to the driver was 75%, with 25% to the railroad, and amended the judgment accordingly. The amended judgment was affirmed. View "THOMAS VS. BNSF RAILWAY COMPANY" on Justia Law