Justia Louisiana Supreme Court Opinion Summaries

The Louisiana Supreme Court granted certiorari to consider the continuing validity of the doctrine of absolute prosecutorial immunity, adopted in Knapper v. Connick, 681 So. 2d 944 (1996). This case presented the issue of whether Louisiana law recognized a cause of action for claims asserted against an assistant district attorney (“ADA”), who, during the plea and sentencing phase of a prosecution, misrepresents, either directly or by omission, a victim’s preference as to the sentence to be imposed upon a defendant, and thereafter, attempts to conceal this alleged misconduct. A secondary question concerned whether a cause of action could be maintained against the district attorney (“DA”) who employed the ADA, under a theory of vicarious liability or for employment-related claims. The Supreme Court reaffirmed its holding in Knapper and further found that, under the circumstances of this case, both the ADA and the DA were entitled to immunity. The Court thus found that the lower courts erred in overruling the defendants’ peremptory exception of no cause of action. View "Jameson v. Montgomery, et al." on Justia Law

The certiorari writ application in this case was granted by the Louisiana Supreme Court to address a purely legal issue: where a defendant’s convictions by a non-unanimous jury were final, but his sentences were still under review at the time Ramos v. Louisiana, 590 U.S. –––– (2020), was decided, is the defendant entitled to a new trial? The answer to this question was determined by whether the matter would be considered to be on “direct review” as contemplated by Louisiana v. Reddick, 351 So. 3d 273 (2022). The Louisiana Supreme Court found that only the direct review of the non-unanimous jury conviction entitled a defendant to a new trial. "Once that review is final, the defendant is not entitled to any further relief under Ramos, irrespective of whether his sentence or resentence is still on appeal." View "Louisiana v. Vaughn" on Justia Law

Plaintiff sought insurance coverage under an all-risks commercial insurance policy for business income losses during the COVID-19 pandemic. Finding no “direct physical loss of or damage to property” caused by COVID-19, the Louisiana Supreme Court reversed the appeal court and reinstated the trial court judgment denying coverage. View "Cajun County, LLC et al. v. Certain Underwriter at Llloyd's, London, et al." on Justia Law

The property at issue in this case was a small parcel, about 50-feet square, located in the middle of a block in the French Quarter. "Lot AA" was bounded on its north and east sides by an alley that accessed Conti Street to the east. On its west and south sides, the lot was contiguous with three parcels identified as lots 8, A, and B, currently owned by defendant, 1025 Bienville, LLC. Nearby lot 3, bordered on its north and west sides by the alley and fronting on Conti Street, was owned by 1026 Conti Condominiums, LLC, a sister entity of the plaintiff, 1026 Conti Holding, LLC. Bienville and Conti Holding both claimed ownership of lot AA. A dispute arose between the neighbors when Bienville refused to allow the owner of Conti Condominiums, Robert O’Brien, to park on lot AA. In a precursor to the present litigation, Conti Condominiums sued Bienville, alleging a servitude acquired by Conti Condominiums in the purchase of lot 3 granted it the right to park on lot AA. The courts disagreed and found the servitude does not extend to parking. During the course of the proceeding, O’Brien learned the public records did not contain a sell-out of lot AA. O’Brien located two of the lot's previous titleholder's grandchildren and paid them $100 to transfer their interest in the property to Conti Holding, a newly formed entity also owned by O’Brien. The heirs quit-claimed their interest to Conti Holding without warranty in an instrument signed by the parties in 2015. O’Brien also got a judgment of possession in the former titleholder's succession recognizing the grandchildren as the titleholder's only living heirs and reflecting the transfer of their interest in lot AA to Conti Holding. Relying on these documents, Conti Holding filed the underlying proceeding against Bienville seeking a judgment declaring Conti Holding the owner of lot AA. The Louisiana Supreme Court found Bienville acquired ownership of the lot by ten-year acquisitive prescription. View "1026 Conti Holding, LLC VS. 1025 Bienville, LLC" on Justia Law

In July 2019, Plaintiffs Suzanne Farrell and her husband, Joseph Farrell, were traveling to Galveston, Texas, when they stopped to refuel at a Circle K Store in Pineville, Louisiana. While Mr. Farrell pumped gas, Mrs. Farrell decided to take their dog for a walk. She ultimately chose a grassy area located at the edge of the Circle K parking lot. In order to reach this area of grass, Mrs. Farrell had to traverse a pool of water. The water extended approximately the length of a tractor-trailer and was draining to the low spot of the parking lot. Mrs. Farrell walked to the narrowest part of the water—approximately one foot across— and attempted to step over the water. She was unsuccessful, and she fell and sustained personal injury. Mr. and Mrs. Farrell subsequently filed this personal injury lawsuit against Circle K and the City of Pineville. Defendants jointly moved for summary judgment, arguing that they were not liable on the ground that the alleged hazardous condition was open and obvious. Plaintiffs opposed the motion, arguing that the hazard was not the pool of water, but the slippery substance hidden in the water, and that made the hazard not open and obvious. The trial court denied Defendants’ motion for summary judgment, finding “that there exist issues of material fact regarding whether a reasonable person should have seen the mold/mildew/algae/slime present in the water puddle at issue.” The Louisiana Supreme Court disagreed with the district court's decision, reversed and rendered judgment in favor of defendants. View "Farrell v. Circle K Stores, Inc. et al." on Justia Law

The district court awarded damages to plaintiff Lashondra Jones who was allegedly injured when she stepped on a wooden pallet with an attached pallet guard, holding a bulk watermelon bin, to reach a watermelon in the bottom of the bin, and the pallet guard collapsed. Defendant Market Basket Stores, Inc. appealed, and the appellate court reversed the award, finding manifest error in the factual findings of the district court requiring de novo review and concluding that the watermelon display did not present an unreasonable risk of harm to plaintiff. After review, the Louisiana Supreme Court concluded there was no manifest error in the district court’s finding of negligence on the part of the defendant; therefore, the appellate court erred in its ruling. View "Jones v. Market Basket Stores, Inc." on Justia Law

Matthew Morgan, an inmate assigned to the Concordia Parish Correctional Facility and under the supervision of the Sheriff of Concordia Parish, escaped from his trustee work assignment at the Concordia Parish courthouse. Morgan walked to a nearby Wal-Mart parking lot where he attempted to carjack and kidnap Sharon Tisdale. Tisdale was diagnosed with post-traumatic stress disorder as a result of the incident, and filed suit against Morgan and the Sheriff. Following a trial, the district court found both defendants liable, apportioning 90 percent of the fault to the Sheriff and 10 percent to Morgan. The district court awarded Tisdale $250,000 in general damages. The issue this case presented for the Louisiana Supreme Court's review was whether the district court erred in its apportionment of fault, and whether the court abused its discretion in awarding damages. The Supreme Court determined fault should have been reallocated, decreasing the Sheriff’s fault to 50 percent and increasing Morgan’s fault to 50 percent. However, the Court found no abuse of discretion in the award for general damages. View "Tisdale v. Hedrick, et al." on Justia Law

Plaintiffs Yasha Clark and Morgan Walker petitioned to disqualify defendant Stephanie Bridges as a candidate for the office of Orleans Parish Civil District Court Judge, Division B. Plaintiffs alleged that Bridges falsely certified that she had filed her state and federal income taxes for the prior five years. The specific issue before the Louisiana Supreme Court in this matter was whether Bridges' 2021 state tax returns were electronically filed at the time she filed her notice of candidacy. Bridges used a tax preparation business, Mobile Tax, LLC, to have her 2021 federal and state tax returns filed electronically. Mobile Tax gave Bridges a letter on company letterhead that the tax returns were filed. Approximately one hour later, Bridges filed a sworn notice of candidacy to declare her intent to run for District Court Judge. In a letter from the Louisiana Department of Revenue (LDR), the agency indicated it did not have a 2021 tax return on file for Bridges; a representative testified she did not know if the LDR was capable of seeing the mechanism by which the tax returns were filed or how long it takes the LDR to process and record the filing of electronically filed returns. The federal Internal Revenue Service was able to confirm receipt of the electronically filed federal return. After review, the Louisiana Supreme Court reversed the judgment sustaining an objection to candidacy. Defendant's candidacy was reinstated because, at the time of her candidacy, she complied with the statutory law and administrative regulations related to filing her income tax return. View "Clark, et al. v. Bridges, et al." on Justia Law

Lake Charles Rubber and Gasket Co., L.L.C. ("Lake") and its sole owner, Vesta Balay Johnston (collectively, Plaintiffs), and Gulf Coast Rubber and Gasket, L.L.C. ("Gulf') and Bryan Vincent (collectively, Defendants), both appealed certain court of appeal rulings. Defendants asserted the court of appeal failed to correctly apply the manifest error standard of review in reversing the district court's findings that certain Lake information in Gulf's possession did not constitute "trade secrets" or that their misappropriation was not otherwise a violation of the Louisiana Unfair Trade Secrets Act ("LUTSA"). They further argued the court of appeal erred in increasing the damages award from $700,000 to $19,574,884, i.e., a multiple of nearly 28, where ample evidence in the record supported the district court's judgment as to damages. Plaintiffs argued the court of appeal erred on rehearing by eliminating the treble damages applied to its award for unjust enrichment and dismissing Johnston's claim for diminution in value of her ownership interest in Lake. The Louisiana Supreme Court reversed the court of appeal in part as to its finding that Lake's parts numbering system and descriptions constituted a trade secret under LUTSA. Furthermore, the Court reversed the court of appeal as to the increase in the amount of lost profit damages. The case was remanded to the district court for a recalculation of lost profit damages giving consideration to the violations of LUTSA related to Gulf's misappropriation of Lake's customer lists and inventory usage history with respect to the Sasol customer contract. The Court affirmed in all other respects and remanded for further proceedings. View "Johnson, et al. v. Vincent, et al." on Justia Law

This matter arose from a 2006 class action suit instituted by Steve Crooks and Era Lee Crooks (“Class Plaintiffs”) against the State through the Louisiana Department of Natural Resources (“LDNR”) concerning the ownership of riverbanks in the Catahoula Basin and subsequent mineral royalty payments. The Louisiana Supreme Court granted review in this case to address whether mandamus may lie to compel the State to pay a judgment rendered against it for mineral royalty payments. Finding that the payment of a judgment concerning the return of mineral royalties received by the State required legislative appropriation, an act that is discretionary in nature, the appellate court erred in issuing the writ of mandamus. View "Crooks, et al. v. Louisiana, Dept. of Nat. Resources" on Justia Law