Justia Louisiana Supreme Court Opinion Summaries

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

This case involves a motor vehicle accident that occurred on March 31, 2017, in Calcasieu Parish. Elvis Dean Thompson, driving an 18-wheeler for Terry Graham Trucking, rear-ended Tracey Day's vehicle, which then struck another vehicle driven by Teresa Jeffries. Thompson's truck also collided with a vehicle driven by Daniel Guidry. Tracey Day and her husband, Bradley Day, sued Thompson, Terry Graham Trucking, and their insurer, Prime Insurance Company, for damages. Bradley Day also claimed loss of consortium. The Days' case was consolidated with Jeffries' case but was later severed.The district court set the trial for September 20, 2021, but it was postponed to January 3, 2022, due to Hurricane Ida. The court ruled that no further discovery would be allowed. On the first day of the trial, the Days requested that Tracey Day be excused from attending the trial except for her testimony, citing her inability to sit for long periods. The defense objected but the court granted the request. During the trial, the defense obtained surveillance video of Tracey Day, which they argued was necessary to impeach her testimony. The district court excluded the video and the testimony of the private investigator who recorded it, citing the late production and the closed discovery period. The jury awarded the Days $3,926,849.17, and the defendants appealed.The Louisiana Supreme Court reviewed whether the district court erred in excluding the surveillance evidence. The court found that the district court abused its discretion by not conducting an in camera review of the evidence. However, after conducting its own review, the Supreme Court determined that the surveillance did not contradict Tracey Day's testimony and was not impeachment material. Therefore, the exclusion of the evidence was proper, and the judgment was affirmed. View "DAY VS. THOMPSON" on Justia Law

William Campbell, a guest at the Windsor Court Hotel in New Orleans, was robbed and injured in the hotel’s courtyard on Christmas Day, 2008. He filed a lawsuit against the hotel and associated entities, alleging negligence and strict liability due to the hotel’s failure to provide adequate security and maintain a safe environment.The trial court granted summary judgment in favor of the defendants, finding that Campbell failed to prove the hotel had a legal duty to protect him from the specific criminal act. The Court of Appeal reversed this decision, citing genuine issues of material fact regarding the foreseeability of the incident and the hotel’s duty to protect its guests.The Supreme Court of Louisiana reviewed the case and conducted a de novo review. The court reaffirmed that an innkeeper has a duty to take reasonable precautions to protect guests from criminal acts of third parties. However, it found that the scope of this duty did not encompass the specific harm Campbell suffered. The court noted that there had been no prior criminal activity at the hotel in twenty years, and Campbell’s own actions—approaching an unknown vehicle and displaying a large sum of money—were unforeseeable and contributed to the incident.The Supreme Court of Louisiana vacated the appellate court’s judgment and reinstated the trial court’s judgment, granting summary judgment in favor of the defendants. The court held that while the hotel owed a duty to provide a reasonably safe environment, the scope of this duty did not include the risk of harm Campbell encountered due to his own actions. View "CAMPBELL VS. ORIENT-EXPRESS HOTELS LOUISIANA, INC." on Justia Law

In November 2019, Kathleen Welch was admitted to Tulane Medical Center for acute pancreatitis and diabetic ketoacidosis. After her discharge, she was admitted to BridgePoint Healthcare for rehabilitation, where she developed pressure ulcers. She was later transferred to United Medical Physical Rehabilitation Hospital, where her condition persisted. Welch filed a claim for injuries related to her pressure ulcers, naming BridgePoint and United Medical as defendants. United Medical, not being a qualified healthcare provider under the relevant statute, faced a lawsuit alleging negligence.United Medical filed an exception of no cause of action, citing La. R.S. 29:771(B)(2)(c)(i), which limits liability to gross negligence or willful misconduct during a public health emergency. The trial court granted the exception, applying the gross negligence standard but did not rule on the statute's constitutionality. Welch appealed, and the appellate court upheld the trial court's application of the statute but remanded the case for a ruling on its constitutionality. On remand, the trial court found the statute constitutional, and Welch sought supervisory review.The Supreme Court of Louisiana reviewed the case and affirmed the lower court's decision. The court held that La. R.S. 29:771(B)(2)(c)(i) is constitutional, as it is rationally related to a legitimate government interest in ensuring access to healthcare during a public health emergency. The court found that the statute does not violate the Louisiana Constitution's due process or access to courts provisions and is not a prohibited special law. The statute's application to all healthcare providers equally and its rational basis for limiting liability during emergencies were key factors in the court's decision. View "WELCH VS. UNITED MEDICAL HEALTHWEST-NEW ORLEANS L.L.C." on Justia Law

The case involves a challenge to the constitutionality of 2021 La. Acts, No. 437, which legalized historical horse racing without requiring voter approval in the affected parishes. Historical horse racing uses an algorithm based on the results of previously run horse races, with bets made at terminals similar to slot machines. Plaintiffs, residents of five parishes where historical horse racing could be conducted, argued that the Act violated Article XII, section 6(C) of the Louisiana Constitution, which requires voter approval for any new form of gaming not specifically authorized before the effective date of the amendment.The 19th Judicial District Court, Parish of East Baton Rouge, found that the plaintiffs had standing to challenge the Act and granted summary judgment in their favor. The court declared historical horse racing a new form of gaming requiring local voter approval and declared Act 437 unconstitutional. The defendants appealed the decision.The Supreme Court of Louisiana reviewed the case and affirmed the lower court's decision. The court held that historical horse racing is a new form of gaming not authorized in Louisiana before October 15, 1996, and therefore requires prior voter approval in a local election as mandated by Article XII, section 6(C) of the Louisiana Constitution. The court concluded that Act 437 is unconstitutional for allowing historical horse racing without the required voter approval. View "FREMIN VS. BOYD RACING, LLC" on Justia Law