This case involved the validity of a notarial will executed by John Wallace Frabbiele, who initialed the first two pages of his three-page testament and signed only the last page. The trial court and appellate court upheld the will as valid under La. C.C. art. 1577, but the Louisiana Supreme Court reversed. The court held that the statute requires the testator to "sign his name" on each separate page, and initials alone do not satisfy this mandatory requirement. As a result, the failure to sign each page constitutes a material deviation that renders the testament an absolute nullity.
The case involved Jaylon K. Brown, who was tried and convicted on two counts of second degree murder and manslaughter after a jury trial in Iberville Parish. During the proceedings, the district court removed a juror observed repeatedly sleeping through witness testimony and video evidence despite multiple warnings, replacing her with an alternate. Brown claimed this action, taken outside his presence and without a hearing, violated his constitutional and statutory rights to have his case decided by the jurors selected. The Louisiana Supreme Court affirmed the convictions and sentences, reasoning that the juror's chronic inability to stay awake after interventions constituted grounds for removal and that no hearing was required where defense counsel neither requested one nor timely objected to the procedure.
The case involved a Louisiana parish government seeking insurance coverage for hurricane damage to hundreds of public properties, with the domestic insurers attempting to enforce arbitration clauses requiring proceedings in New York under New York law. The Louisiana Supreme Court addressed three certified questions from a federal district court regarding the validity of such arbitration provisions in surplus lines insurance policies issued to political subdivisions. It held that a 2020 statutory amendment permitting certain forum-selection clauses did not repeal the general prohibition on arbitration clauses in insurance contracts, that a separate statute barring arbitration in public contracts applies to insurance policies, and that equitable estoppel could not be used by one insurer to enforce another's arbitration clause or applied to public bodies without meeting a heightened standard. The court's reasoning rested on principles of statutory interpretation, distinguishing arbitration clauses from venue provisions and emphasizing legislative intent to protect access to Louisiana courts and public contracting rules.
This case involved challenges by defendants Erik Nunez, Brandon Liccardi, and Tyrone Brown to the Orleans Parish Criminal District Court's system for randomly allotting multi-count felony cases to judges, which assigns based on the earliest alleged offense date when that date is uncertain. The defendants moved to quash their allotments, arguing the process violated Louisiana District Court Rule 14.0 and their due process rights by potentially allowing prosecutorial manipulation in selecting judges. The Louisiana Supreme Court held that the allotment method was sufficiently random because it was tethered to the defendants' conduct rather than giving the District Attorney unchecked discretion to choose a judge. The court reversed the Court of Appeal's grants of the motions to quash and orders for re-allotment, reinstated the trial courts' denials of those motions, and remanded for further proceedings, finding no evidence of actual manipulation or prejudice. The decisions otherwise affirmed the Court of Appeal.
This case involved a workers' compensation claim by Calvin Arrant, who was injured in a work-related vehicle accident and sought approval for a lumbar spine MRI recommended by his orthopedic surgeon. After the Office of Workers' Compensation medical director denied the requests twice, Arrant filed a disputed claim form more than 15 days later, leading the hearing officer to sustain the defendants' exception of prescription based on an administrative rule requiring appeals within that timeframe. The Louisiana Supreme Court held that a statutory prescriptive period cannot be shortened by an administrative rule, ruling that the hearing officer erred as a matter of law in dismissing the claim on timeliness grounds. The court reversed and vacated the prescription ruling, remanding for consideration of whether the medical director properly applied the medical treatment guidelines, while affirming the judgment in other respects.
This case involved royalty owners suing mineral lessees and operators for alleged losses of hydrocarbons from two oil and gas wells, claiming the defendants violated the Mineral Code by imprudently operating the wells and damaging the reservoirs. After a bench trial, the district court dismissed the claims with prejudice, finding the plaintiffs had not proven causation and crediting the defendants' experts over the plaintiffs'. The court of appeal reversed, but the Louisiana Supreme Court reinstated the district court's judgment, concluding that the trial court's factual findings and credibility determinations had a reasonable basis in the record and were not manifestly erroneous.
This case involved whether a juvenile court's dismissal with prejudice of delinquency petitions—due to the state's failure to meet statutory deadlines for adjudication under the Children's Code—barred the district attorney from later obtaining a grand jury indictment and prosecuting the same armed robbery and attempted second-degree murder charges in district court. The district court granted the defendant's motion to quash the indictment, but the court of appeal reversed. The Louisiana Supreme Court affirmed, holding that the time limits in La. Ch.C. art. 877 apply exclusively to juvenile court proceedings and do not prevent the district attorney from initiating adult-court prosecution for these serious offenses once exclusive district court jurisdiction attaches via indictment. The court reasoned that the legislature had not imposed such a bar as a penalty for missing juvenile deadlines, distinguishing prior precedent that applied only within juvenile court.
The case was an attorney disciplinary proceeding against Louisiana lawyer Joyce Nanine McCool arising from her assistance to a friend in interstate child custody and intrafamily adoption matters. McCool, who was not admitted to practice in Mississippi, filed Louisiana court petitions, sought emergency custody, pursued writs, and posted an online public petition that criticized the rulings of judges in both states and demanded changes to the proceedings. The Louisiana Supreme Court found these actions violated the Rules of Professional Conduct by making false or reckless statements about judicial integrity and engaging in conduct prejudicial to the administration of justice. The court ordered McCool disbarred, striking her name from the roll of attorneys.
The case concerned a challenge by several individuals to the City of New Orleans' Automated Traffic Enforcement System ordinances, which established an administrative process for adjudicating traffic camera tickets; the plaintiffs claimed the process violated state constitutional due process and access-to-courts rights. After a preliminary injunction was granted and upheld on review, the plaintiffs moved for summary judgment seeking a permanent injunction, relying on their affidavits and prior court rulings. The Louisiana Supreme Court reversed the grant of the permanent injunction, holding that the motion failed to comply with summary judgment requirements because it did not attach or cite sufficient admissible evidence to permit a decision on the constitutional merits. The court therefore declined to address those merits, reinstated the preliminary injunction, and remanded the case.
This case involved a class action lawsuit by patients against PHC-Minden, L.P. d/b/a Minden Medical Center alleging that the hospital violated the Balance Billing Act by routinely seeking to collect full undiscounted medical charges from patients' liability insurance settlements via medical liens, rather than accepting contracted rates from the patients' health insurers. The Louisiana Supreme Court addressed a split among appellate circuits on whether class certification was appropriate for such claims. The Court reversed the Second Circuit and reinstated the trial court's certification of the class, holding that a class action is the superior method for fairly and efficiently resolving the common legal question of the hospital's billing and lien practices. It further found that the plaintiffs had satisfied the remaining requirements for class certification, including numerosity, commonality, typicality, adequacy, and definability. The matter was remanded to the district court for further proceedings.
This case involves the admissibility of evidence of a defendant's prior alleged sexually assaultive behavior in a prosecution for forcible rape under Louisiana law. The trial court excluded evidence of a 1997 incident involving the defendant allegedly holding a knife to a victim's throat and fondling her breasts, ruling that it did not meet the statutory elements of sexual battery and thus was not admissible under La. Code Evid. art. 412.2. The Louisiana Supreme Court reversed, holding that Article 412.2 allows evidence of sexually assaultive behavior that is not limited to offenses explicitly defined by state statute, and that the alleged conduct qualified as such behavior. The court remanded the case for the trial court to apply the balancing test under Article 403 before determining admissibility.
The case concerned whether Paul Massey, convicted in 2007 of felony carnal knowledge of a juvenile and attempted molestation of a juvenile for acts committed in 1994, could earn good time credits for early release from his six-year sentence. A 2006 statutory amendment had narrowed eligibility for such credits and excluded offenders convicted of those crimes. The Louisiana Supreme Court reversed the Court of Appeal and remanded the matter to the Department of Public Safety and Corrections with instructions to recompute the sentence under the pre-2006 law. The court reasoned that applying the amended statute would violate the ex post facto clauses of the U.S. and Louisiana Constitutions by creating a significant risk of prolonging incarceration and increasing the severity of the punishment.
Cynthia Holliday sued the Board of Supervisors of LSU Agricultural and Mechanical College for damages under the Family and Medical Leave Act (FMLA) after being terminated while on leave for a serious health condition, invoking the statute's self-care provision. The Louisiana Supreme Court reversed the district court's denial of the state's exception of no cause of action, granting the exception and remanding the case to allow Holliday an opportunity to amend her petition if possible. The court held that Louisiana retains sovereign immunity from suits based on this FMLA provision. It reasoned that the U.S. Supreme Court's decision in Coleman v. Court of Appeals of Maryland established that the self-care provision does not validly abrogate state sovereign immunity under Section 5 of the Fourteenth Amendment, and that the state's constitutional waiver of immunity in contract or tort does not extend to waiving immunity against this federal cause of action.
The case concerned a defendant convicted of simple burglary of a vehicle who raised Batson challenges to the state's peremptory strikes of three African-American prospective jurors, including one based on prior convictions not disclosed during voir dire. The trial court denied the challenges after accepting the state's race-neutral explanations, but the Court of Appeal reversed the conviction and sentence under the Knighten rule, which required the state to provide evidence supporting its reasons when challenged. The Louisiana Supreme Court reversed the appellate decision, reinstated the conviction and sentence, and overruled the Knighten rule, holding that it improperly undermined the established Batson framework for assessing purposeful discrimination in jury selection without violating equal protection or due process.
The case involved whether the filing of a class action lawsuit in Louisiana state court for damages from a chemical vapor leak suspended the prescription period for individual claims by putative class members even after the case was removed to federal court and class certification was denied. The Louisiana Supreme Court reversed the lower court's decision upholding the defendants' exception of prescription, holding that prescription remained suspended because none of the events specified in Louisiana Code of Civil Procedure Article 596 to resume the running of prescription had occurred. The court reasoned that Article 596 applies to class actions filed in state court, and the subsequent removal to federal court did not trigger the resumption of prescription for the putative class members who later filed individual suits in state court.
The case involved relator Anthony Armstrong's application seeking post-conviction relief from the State of Louisiana. The Louisiana Supreme Court denied the application. The denial rested on procedural bars under La.C.Cr.P. art. 930.8, which imposes time limitations on post-conviction claims, as explained in State ex rel. Glover v. State, along with a citation to La.C.Cr.P. art. 351. Justice Knoll was recused.
This case involved a lawsuit by Global Marketing Solutions, LLC against Blue Mill Farms, Inc. and multiple oil and gas companies, apparently concerning property or related claims in Louisiana. The Louisiana Supreme Court granted the writ application. It remanded the matter to the district court to reconsider its prior rulings based on the precedent established in Eagle Pipe and Supply, Inc. v. Amerada Hess Corporation. Justice Knoll was recused, and Justice Weimer indicated a preference to grant and docket the case for full argument.
This case involves a petition by the Office of Disciplinary Counsel seeking to transfer attorney Clark C. Roy to disability inactive status. The Louisiana Supreme Court had previously reinstated Roy subject to conditions in a recovery agreement, with any violation potentially leading to immediate transfer to inactive status. Roy was found to have violated those conditions by failing to comply with the agreement's terms. Based on that violation, the court ordered his transfer to disability inactive status effective immediately under Supreme Court Rule XIX, § 26(E).
This case involves David Wayne Poydras filing an application for relief against the State of Louisiana in the Supreme Court of Louisiana. The court denied the application on February 10, 2012. The denial was pursuant to La.C.Cr.P. art. 930.8 regarding time limits for post-conviction filings, along with the precedent established in State ex rel. Glover v. State. Justice Knoll was recused from participation in the decision.
The case involved a lawsuit by Wanda Desentz against Dr. David Dunn and East Jefferson General Hospital, apparently arising from medical treatment. The Louisiana Supreme Court denied the writ application, leaving the lower court's decision in place. Justice Knoll indicated she would have granted the writ for further review, while Justice Guidry was recused from the matter. The brief per curiam opinion provided no additional explanation or analysis of the underlying claims.