Justia Louisiana Supreme Court Opinion Summaries

The applicant was convicted of second-degree murder by a Lafourche Parish jury for the shooting death of Deeric Raymond during a confrontation outside the applicant’s home. The incident occurred when Deeric and his brother Javonnie arrived to collect a debt and exchange custody of a child. A physical altercation ensued, resulting in Deeric’s death from a gunshot wound. The central issue at trial was whether the applicant acted in self-defense or was the initial aggressor. The jury rejected the self-defense claim and found the applicant guilty.The trial court sentenced the applicant to life imprisonment without parole. The Louisiana Court of Appeal affirmed the conviction, finding sufficient evidence to support the jury’s rejection of the self-defense claim. The applicant then filed for post-conviction relief, claiming ineffective assistance of counsel. The district court denied relief, stating no new evidence was presented that would have changed the jury’s verdict. The Court of Appeal denied writs without explanation, leading the applicant to seek review from the Supreme Court of Louisiana.The Supreme Court of Louisiana found merit in some of the ineffective assistance of counsel claims. The court determined that the applicant’s trial attorney failed to use available evidence to impeach the testimony of Javonnie, did not consult a forensic expert, and advised the applicant not to testify. These errors were deemed unreasonable and prejudicial, undermining confidence in the trial’s outcome. The court held that the applicant’s counsel’s performance fell below an objective standard of reasonableness and that there was a reasonable probability of a different outcome but for these errors. Consequently, the Supreme Court of Louisiana reversed the district court’s judgment, vacated the conviction and sentence, and remanded the case for a new trial. View "State v. Thomas" on Justia Law

Gerald Williams, an inmate in Louisiana, filed a suit for judicial review after the Louisiana Board of Pardons and Parole revoked his parole. Williams was originally convicted of armed robbery in 1985 and sentenced to 99 years without parole. After serving 28 years, he was released on parole in 2013. In 2021, Williams was arrested for aggravated assault, pleaded guilty to simple assault, and subsequently had his parole revoked. He later claimed his waivers of the revocation hearings were not knowing and voluntary and argued that his parole violation should be considered a "technical violation."The district court dismissed Williams' suit with prejudice, based on a recommendation from a commissioner, for failure to state a claim and because it was perempted under La. R.S. 15:574.11(D). The First Circuit Court of Appeal affirmed the district court's decision.The Supreme Court of Louisiana reviewed the case and addressed three main issues: whether Williams' petition was perempted, whether his procedural due process rights were violated, and whether his parole violation could be classified as a "technical violation." The court found that Williams' petition was perempted as it was filed 507 days after the parole revocation, well beyond the 90-day period allowed by law. The court also determined that Williams' waiver of his revocation hearings was knowing, intelligent, and voluntary, as he had signed and acknowledged the waiver in writing. Lastly, the court held that Williams' parole violation could not be classified as a "technical violation" due to his original conviction for a violent crime and his guilty plea to an intentional misdemeanor directly affecting a person.The Supreme Court of Louisiana affirmed the appellate court's decision to dismiss Williams' petition with prejudice. View "Williams v. Department of Public Safety and Corrections" on Justia Law

Plaintiffs, employees and independent contractors of White Oak Radiator Service, Inc., were injured while performing work at Enable Midstream Partners, LP's natural gas processing plant. The work involved removing and replacing amine and glycol coolers. During the work, a glycol surge tank ruptured, causing injuries. Plaintiffs filed a lawsuit seeking damages for their injuries.The trial court found that the claims of Joey Miller and Davy Dowdy against Enable sounded in tort rather than workers' compensation. The court awarded damages to Mr. Dowdy for injuries to his cervical spine and hearing loss, but found that White Oak bore a greater percentage of fault than assigned by the trial court. The trial court assigned 90 percent fault to Enable and 10 percent to White Oak. Enable appealed, arguing that the plaintiffs' exclusive remedy was under the Louisiana workers' compensation laws and challenging the allocation of fault and damages.The Supreme Court of Louisiana reviewed the case and held that the manual labor exception under La. R.S. 23:1021 (7) does not apply to the employees and independent contractors of an independent contractor. Therefore, plaintiffs' claims against Enable sound in tort. The court found no manifest error in the trial court's award of damages to Mr. Dowdy for his cervical spine injuries and hearing loss. However, the court found that the trial court erred in the apportionment of fault and amended the judgment to assign 70 percent fault to Enable and 30 percent fault to White Oak. The trial court's judgment was affirmed as amended. View "McBride v. Old Republic Insurance Co." on Justia Law

23rd Psalm Trucking, L.L.C. entered into a four-year contract with the Madison Parish Police Jury on July 14, 2014, to collect and dispose of residential waste. The contract was extended for an additional three years, set to expire on July 14, 2021. However, due to fiscal concerns, the Police Jury rebid the contract in June 2020 and awarded it to another contractor, effective January 1, 2021. Psalm Trucking sued for breach of contract and unfair trade practices, claiming an estimated loss of $385,235.50.The trial court granted summary judgment in favor of the Police Jury, finding the contract null and void under La. R.S. 39:1410.60 (A) because it was not approved by the State Bond Commission. The court also rejected Psalm Trucking’s detrimental reliance claim, noting the company did not seek legal advice before contracting. The Court of Appeal affirmed, agreeing that the Bond Commission’s approval was required for multi-year contracts without a non-appropriation clause.The Supreme Court of Louisiana reviewed the case and affirmed the lower courts' decisions. The court held that La. R.S. 33:4169.1 and La. R.S. 39:1410.60 must be read together, requiring Bond Commission approval for contracts that constitute debt. The court found the four-year contract constituted debt and was null and void without the Bond Commission’s approval. The court also agreed that Psalm Trucking failed to prove detrimental reliance against a governmental agency. The judgment of the Court of Appeal was affirmed. View "23rd Psalm Trucking, L.L.C. v. Madison Parish Police Jury" on Justia Law

D.D., a juvenile, was adjudicated delinquent for committing second-degree rape at the age of fourteen and was committed to the custody of the Office of Juvenile Justice until his twenty-first birthday. Upon release, he was required to register as a sex offender. D.D. challenged the constitutionality of this registration requirement, arguing it violated the Sixth and Eighth Amendments of the U.S. Constitution. The juvenile court denied his motion.D.D. appealed to the Court of Appeal, First Circuit, which affirmed both the adjudication and the denial of his constitutional claims. D.D. then sought review from the Supreme Court of Louisiana, which granted his writ application.The Supreme Court of Louisiana held that the sex offender registration requirement for juveniles does not constitute cruel and unusual punishment under the Eighth Amendment, as it is a civil regulatory measure intended to protect public safety rather than a punitive action. The court also found that the registration requirement does not implicate the Sixth Amendment's right to a jury trial, as juvenile proceedings are fundamentally different from adult criminal trials and do not require a jury trial for due process. The court affirmed D.D.'s adjudication and the denial of his motion to declare the registration requirement unconstitutional. View "In re D.D." on Justia Law

John and Analise Noehl were indicted for second-degree murder and cruelty to a juvenile after their seven-week-old son, D.N., was brought to the hospital with life-threatening injuries, including a skull fracture and healing rib fractures. Hospital staff alerted law enforcement due to the suspicious nature of the injuries. Detectives arrived, spoke with the parents at the hospital, and conducted separate interviews in a nearby room. The interviews were calm, lasted under 20 minutes each, and concluded with the parents being allowed to leave to accompany their child to another hospital.The 19th Judicial District Court granted the defendants’ motion to suppress the statements made during these interviews, finding that the parents were subjected to custodial interrogation without having received Miranda warnings. The court reasoned that the circumstances—such as being directed into a separate room, the presence of a homicide detective, and the officers’ actions—amounted to a significant restraint on the defendants’ freedom. The Louisiana First Circuit Court of Appeal denied the State’s writ application, leaving the suppression in place.The Supreme Court of Louisiana reviewed the case and reversed the trial court’s decision. The court held that, under the objective standard established by United States Supreme Court precedent, the defendants were not in custody for Miranda purposes during the hospital interviews. The court emphasized that the relevant inquiry is how a reasonable person in the suspects’ position would have understood the situation, not the subjective beliefs of the officers or the defendants. Because the interviews were brief, non-coercive, and the parents were free to leave afterward, the court concluded that Miranda warnings were not required. The case was remanded for further proceedings. View "STATE OF LOUISIANA VS. NOEHL" on Justia Law

The plaintiff, Kelly O. Orgeron, sought a community property share of $16,949,000 in liquidated damages paid to her ex-husband, Edward J. Orgeron, Jr., upon the termination of his employment as a college football coach in 2021. The liquidated damages were a contractual benefit guaranteed by his employer, Louisiana State University (LSU), effective January 14, 2020, before the defendant filed for divorce on February 26, 2020. The agreements relevant to this case included a Binding Term Sheet, an Employment Agreement, and a Termination Agreement, all of which had provisions regarding liquidated damages upon termination without cause.The trial court did not award the plaintiff a share of the liquidated damages, interpreting the January 2020 Binding Term Sheet as an agreement to agree rather than a binding contract. The Court of Appeal, First Circuit, upheld this decision.The Supreme Court of Louisiana reviewed the case and concluded that the trial court erred in its interpretation. The court held that the January 2020 Binding Term Sheet was a binding and enforceable contract, and the subsequent Employment Agreement continued and confirmed the termination-without-cause provisions. Both agreements were effective during the existence of the community property regime between the plaintiff and the defendant, making the liquidated damages a community asset.The Supreme Court of Louisiana reversed the district court's judgment in favor of the defendant and rendered judgment in favor of the plaintiff, awarding her a one-half share of the net liquidated damages, amounting to $8,134,500. View "Orgeron v. Orgeron" on Justia Law

Kenneth and Doreen Miller entered into a contract with Foundation, Elevation & Repair, LLC (FER) in 2010 for home elevation and foundation work. They also hired Direct Source Home Renovation, LLC (DSHR), owned by the same individual as FER. The Millers' home was allegedly damaged before the renovation was completed, leading them to fire FER. In 2012, FER filed a petition against the Millers for specific performance and declaratory judgment. The Millers responded with exceptions, claiming they were denied a certificate of occupancy due to the damage.After a period of inactivity, the Millers reset their exceptions in 2015, leading to a consent judgment dismissing FER's actions. In 2016, the Millers filed exceptions, an answer, affirmative defenses, and a reconventional demand against FER, including third-party demands against DSHR. After another period of inactivity, the Millers obtained a default judgment against FER and DSHR in 2019. In 2022, the Millers filed a motion to confirm the default judgment, which was denied by the trial court. Subsequently, FER and DSHR filed a motion to dismiss the Millers' action on grounds of abandonment, which the trial court granted.The Court of Appeal affirmed the trial court's dismissal of the Millers' claims against FER but reversed the dismissal against DSHR, finding that DSHR's filing of an answer after the abandonment period constituted a waiver of abandonment. The Supreme Court of Louisiana reviewed the case and reversed the Court of Appeal's decision. The Supreme Court held that DSHR's general denial answer did not constitute a renunciation of abandonment, as it did not clearly demonstrate an intent to proceed with the litigation. The court reinstated the trial court's judgment in favor of DSHR, dismissing the Millers' claims as abandoned. View "FOUNDATION ELEVATION & REPAIR, LLC VS. MILLER" on Justia Law

James and Kim McCormick own a 128.75-acre tract in Bossier Parish, Louisiana, accessed by a private driveway from Modica Lott Road. The property was part of a larger tract subdivided without adhering to the Bossier Parish Subdivision Code, which requires a plat description for split-out tracts. The McCormicks' deed, recorded in 2014, did not comply with these regulations. After a fire damaged their home in 2018, they applied for a building permit in 2020, which was denied by the Bossier Parish Police Jury (BPPJ) due to non-compliance with subdivision regulations.The McCormicks filed a mandamus action against Joe E. Ford, the Parish Engineer, seeking a court order for the permit. The trial court ruled in favor of the McCormicks, requiring the BPPJ to issue the permit, subject to certain conditions regarding the driveway. The Court of Appeal affirmed the trial court's decision to issue the permit but removed the conditions, stating that the five-year prescriptive period for enforcing subdivision regulations had expired, making the property non-conforming.The Supreme Court of Louisiana reviewed the case to determine if the McCormick Tract enjoyed non-conforming status under La. R.S. 9:5625, which provides a five-year prescriptive period for enforcement actions. The Court held that the prescriptive period began when the deed was recorded in 2014, and since no action was taken within five years, the property attained non-conforming status. Consequently, the McCormicks were entitled to the building permit without additional conditions. The Court affirmed the Court of Appeal's decision, confirming that the McCormick Tract complied with relevant statutes and regulations. View "MCCORMICK VS. FORD" on Justia Law

The defendant, Davieontray Lee Breaux, was indicted on two counts of first-degree murder and three counts of attempted first-degree murder. The State issued a notice to seek the death penalty for the first-degree murder charges. Breaux filed a motion to quash the indictment, arguing misjoinder of offenses under various legal provisions, including the Louisiana Constitution. The trial court denied the motion, reasoning that since all convictions now require unanimity, the charges could be tried together.The Louisiana Third Circuit Court of Appeal denied Breaux's application for supervisory writs. Breaux then applied to the Louisiana Supreme Court, which granted the writ to determine whether prosecutors may join capital felony charges with other felony charges.The Louisiana Supreme Court held that prosecutors cannot join capital felony charges with other felony charges. The court emphasized that the Louisiana Constitution and nearly a century of jurisprudence prohibit such joinder. The court noted that the plain text of the Louisiana Constitution, specifically Article I §17, establishes distinct categories of felony trials and does not permit the joinder of capital and non-capital offenses. The court reversed the trial court's decision and remanded the case for further proceedings consistent with its opinion. View "STATE OF LOUISIANA VS. BREAUX" on Justia Law