Justia Louisiana Supreme Court Opinion Summaries

The Supreme Court was asked to determine whether the district court erred in declaring La. R.S. 15:560 et seq. unconstitutional. Defendants Bryan Golston, Paul Baker, Calvin Watson, Lloyd Dell and Reginald Jackson were soon-to-be-released sex offenders who had undergone the Sex Offender Assessment Panel (SOAP) process pursuant to La. R.S. 15:560 et seq. The district court found that the law was unconstitutionally vague as applied to the Defendants. Upon careful consideration of the legislative history of the SOAP process, the Supreme Court found the law to be a regulatory rather than criminal statutory scheme, and not subject to a void-for-vagueness analysis. Furthermore, even after applying a due process analysis, the Court found no violations. Accordingly, the Court reversed the lower court in each of the Defendants' cases and remanded the cases for further proceedings. View "Louisiana v. Golston" on Justia Law

Central to this case was the issue of whether it is sufficient to serve only the head of a state agency or to also serve the attorney general and the office of risk management when a tort action is brought against the agency. In May 2003, Plaintiff Regina Whitley was five months pregnant when she was in an automobile accident. In July 2003, she delivered a stillborn infant. She filed a medical malpractice suit against the state hospital that treated her immediately following the accident. At the time of filing, Plaintiff requested service of process only on the hospital's chairman. Two and a half years later, the attorney general and the office of risk management received faxed-copies of the complaint. The hospital moved to dismiss, citing insufficiency of service of process. After a hearing, the trial court denied the hospital's motion to dismiss. Upon review, the Supreme Court found that the initial service on only the hospital was sufficient and that the subsequent service on the attorney general and office of risk management cured the hospital's exception of insufficiency of service. The Court affirmed the lower courts' decisions. View "Whitley v. Louisiana" on Justia Law

The State charged Defendant John Mathieu with second degree kidnapping after an incident which Defendant, armed with a gun, confronted his ex-wife in a parking lot at her place of employment, forced her into her car and made her drive out of state. After a trial by jury, Defendant was found guilty as charged. Defendant conducted portions of the trial in his own right, including the cross-examination of his ex-wife and other State witnesses, which his court-appointed attorney conducted jury selection and other portions of the trial. Defendant was sentenced to thirty years' imprisonment at hard labor with the first two years without probation or parole. On appeal, the Fifth Circuit conditionally affirmed Defendant's conviction and sentence, but remanded the case to the trial court to determine whether Defendant made a clear and unequivocal request to represent himself and whether the judge made sufficient inquiries into Defendant's competency to waive counsel and represent himself. Upon review of the trial record, the Supreme Court found that nothing in the record suggested that Defendant was not capable of choosing his "hybrid" representation knowingly and voluntarily. The Court affirmed Defendant's conviction and sentence. View "Louisiana v. Mathieu" on Justia Law

The State charged Defendant Mervin White with driving while intoxicated. After a trial by jury in 2008, he was found guilty as charged. The trial court sentenced him to 20 years' imprisonment at hard labor without opportunity for probation or parole. The appellate court affirmed Defendant's conviction, but vacated his sentence as excessive and reduced it to a term of ten years. The State appealed, arguing that the evidence supported Defendant's 20-year sentence. Upon review of the applicable legal authority, the Supreme Court found that though Defendant's sentence fell within the upper range of sentences, it did not suggest an arbitrary departure "from a sentencing norm that might indicate disproportionate punishment." Accordingly, the Court reversed the appellate court and reinstated Defendant's 20-year sentence. View "Louisiana v. White" on Justia Law

A New Orleans bank robbery in 1984 ended with the death of a Tangipahoa Parish Sheriff's deputy. A unanimous jury found Defendant Thomas Sparks, Jr. guilty of first-degree murder in the deputy's death. At the penalty phase of the trial, the jury unanimously returned a death sentence. Defendant raised twenty-three assignments of error on appeal. After a thorough review of the law and evidence, the Supreme Court affirmed Defendant's murder conviction, and conditionally affirmed the imposition of the death sentence. The Court remanded the case to the district court for an evidentiary hearing on whether Defendant received effective assistance of counsel at the penalty phase of his trial.