Walter B. Hamlin

This case involved a dispute between the widow of a deceased employee and his employer, Bethlehem Steel Corporation, over workers' compensation benefits. The husband died in a 1963 work-related accident at a NASA facility, after which the employer paid benefits until stopping following the widow's $15,000 settlement with third-party tortfeasors that included an indemnity clause regarding potential reimbursement claims. The trial court ruled for the plaintiff, but the Court of Appeal reversed and dismissed the suit; the Supreme Court granted certiorari to review whether the third-party compromise affected the employer's reimbursement rights under state law. The court examined La.R.S. 23:1102 and 23:1103, which govern subrogation and provide that compromises with third parties do not bind the employer unless it assents, along with the specific terms of the release that reserved rights against the employer.

labor & employmenttorts & liability

The case involved Billy J. Taylor's conviction and death sentence for aggravated kidnapping under Louisiana law. On appeal and rehearing, the defendant challenged multiple aspects of the trial, including the exclusion of jurors opposed to capital punishment, the questioning of prospective jurors about anticipated evidence of rape and robbery, the denial of a challenge to a juror friendly with the victims, the exclusion of hospital records on the defendant's sanity, the exclusion of women from the jury venire, and the constitutionality of the death penalty. The Louisiana Supreme Court held that many claims were abandoned or moot in light of Furman v. Georgia, that excluded jurors did not serve so no prejudice occurred, and that any error in excluding records caused no substantial harm, resulting in affirmance of the conviction and sentence.

criminal lawprocedure

In State v. Edgecombe, the Louisiana Supreme Court reviewed the convictions of William F. Edgecombe Jr. for aggravated rape and aggravated kidnapping, along with his death sentence, based on separate indictments tried together. The defendant raised numerous bills of exceptions, primarily challenging the trial court's denial of pretrial access to physical evidence, clothing, and scientific test results (including chemical and medical reports) in the state's possession, as well as motions for a new trial, arguing that withholding this information violated his rights to a fair trial and effective counsel. The court held that an accused generally has no right to pretrial inspection of the prosecution's evidence except for a written confession, distinguishing this from cases involving analysis of alleged contraband, and found no evidence of state deception or undue surprise. It affirmed the convictions after examining the record and finding no reversible error in the rulings.

criminal lawprocedure

This case arose from a fatal 1970 nighttime collision in which the plaintiff's son drove into the side of a stopped, unlighted boxcar blocking a street crossing in Alexandria, Louisiana; the plaintiff sued the railroad and two employees for negligence in parking the train without warnings or signals. The trial court granted summary judgment for the defendants on grounds of the driver's contributory negligence as a matter of law under prior precedent, and the Court of Appeal affirmed. The Louisiana Supreme Court reversed and remanded, holding that the record presented genuine issues of material fact about whether the driver could reasonably have seen the obstruction and whether unusual circumstances excused application of the contributory-negligence rule, making summary judgment improper without supporting affidavits or further evidence.

torts & liabilityprocedure

The case concerned the validity of a search warrant for defendant Gary Hightower's apartment based on an affidavit from police officers describing a confidential informant's marijuana purchase there on November 30, 1971; the warrant was issued and executed on December 8, 1971, leading to seizure of suspected marijuana and charges of attempted possession. The district court granted the defendant's motion to suppress the evidence, concluding that the nine-day delay rendered the information stale and that references to a separate transaction in an adjacent apartment did not establish probable cause. The Louisiana Supreme Court reversed, holding that the affidavit sufficiently demonstrated probable cause for a continuing narcotics operation at the premises and that the delay of nine days was not remote under the circumstances or the ten-day execution limit in the Code of Criminal Procedure. The court emphasized that probable cause requires facts showing the contraband was likely still present at the time of the warrant, which the ongoing-association details and investigative context supported here.

criminal lawprocedure

The case involved defendant Jimmy Michael McCauley's appeal from his conviction for murder and death sentence under Louisiana law, raising twelve bills of exceptions primarily concerning jury selection and the admissibility of his confession. The challenged rulings included the trial court's refusal to permit defense questions during voir dire about prospective jurors' predispositions toward specific sentences such as death versus life imprisonment or manslaughter, as well as disputes over whether the defendant's signed statement was voluntary and properly authenticated. The court examined claims of prejudice from exhausted peremptory challenges and the foundation laid for the confession, applying standards from prior cases like State v. Henry while reviewing the discretion afforded to the trial judge on juror qualification and evidentiary matters.

criminal lawprocedure