Harry T. Lemmon

This case is a direct appeal from Cedric Jacobs's conviction for first-degree murder and death sentence arising from the shooting of Jason Oberling during an armed robbery in a restaurant parking lot. The principal issues on appeal were the prosecutor's allegedly racially motivated use of peremptory challenges during voir dire, claims of prosecutorial misconduct that prevented presentation of exculpatory evidence, and the admission of other crimes evidence in the guilt phase. The Louisiana Supreme Court rejected the Batson challenges, finding that objections to the first three strikes were untimely and that the prosecutor provided race-neutral explanations for the remaining strikes, while also holding that the other claims did not warrant reversal. The court affirmed the conviction and sentence after reviewing the sufficiency of the evidence linking Jacobs to the crime, including ballistic matches, eyewitness accounts, and items found on the defendant.

criminal lawcivil rightsprocedure

This case involved a former state prisoner's tort action against the Louisiana Department of Public Safety and Corrections for serious personal injuries sustained while performing renovation work at a correctional facility under DOC instructions. The State sought dismissal on the grounds that the plaintiff had not first exhausted the Corrections Administrative Remedy Procedure (CARP) under La.Rev.Stat. 15:1171-1179, which requires inmates to file claims administratively within thirty days and subjects decisions to limited judicial review. The Supreme Court of Louisiana granted certiorari to address whether CARP violates La. Const. art. V, § 16(A) by divesting district courts of their original jurisdiction over civil matters. The court held that the statute and implementing rules are unconstitutional as applied to inmate tort claims because they transfer original jurisdiction over these civil actions to an executive agency and impermissibly shorten the time for filing suit. The core reasoning centered on the constitutional text vesting district courts with original jurisdiction in all civil matters except workers' compensation and other specifically designated categories.

criminal lawproceduretorts & liability

The case concerned an expropriation action by the City of Baton Rouge and Parish of East Baton Rouge to acquire land owned by Johnca Properties for a road realignment project, in which the City-Parish sought to use expedited "quick taking" procedures under La.Rev.Stat. 48:441-460 via a local services agreement and references to DOTD statutes. The trial court denied the owner's motion to dismiss and allowed the quick taking based on the agreement, but the court of appeal dismissed the suit after finding multiple deficiencies in the petition and attachments that failed to meet the strict statutory requirements for invoking the procedure. The Supreme Court reviewed the relevant statutes, including La.Rev.Stat. 33:1329 and 48:1259, and addressed whether local authorities could utilize the quick taking process and what compliance was necessary.

propertyprocedure

The case involved a class action by New Orleans firefighters challenging Civil Service Commission rules that limited annual leave accrual and carryover under a 'use it or lose it' policy, provided fewer annual leave days than required, and granted less frequent and lower longevity pay increases than mandated by state law. The trial court granted partial summary judgment to the firefighters on liability for back and future pay, which the court of appeal affirmed. The Louisiana Supreme Court held that La. Rev. Stat. 33:1991-1999 set minimum benefits that could not be restricted by Commission rules, as the Legislature's plenary authority over firefighter compensation prevails over the Commission's power to adopt uniform pay scales, requiring the statutes to control where the two conflict. The court therefore upheld the firefighters' entitlement to the full statutory annual leave and longevity pay calculations.

labor & employment

This case involved riverboat gaming operators who sued the Louisiana Department of Revenue and Taxation for a refund of sales and use taxes paid under protest on gaming equipment such as slot machines and surveillance systems installed during vessel construction. The taxpayers claimed an exemption under La. Rev. Stat. 47:305.1A for materials that become component parts of vessels, relying on initial representations from a Department task force that the equipment qualified. Lower courts held that the equipment did not qualify for the exemption but ruled that detrimental reliance and equitable estoppel barred the Department from collecting the taxes. The Supreme Court of Louisiana decided that the taxes were due and that the doctrines of detrimental reliance and estoppel did not apply to prevent collection, even after the Department's change in position. The core reasoning was that the statute and administrative interpretations did not support binding estoppel against the state in this tax context, and the taxpayers were not entitled to relief from the non-punitive taxes owed.

taxesbusiness & regulatory

The case involved a dispute over whether a Louisiana court retained jurisdiction to modify a child support order after the parents and children had all relocated to other states. The Louisiana Supreme Court held that the original court lost continuing exclusive jurisdiction to modify the order under the Uniform Interstate Family Support Act once all parties moved away, though it retained authority to enforce the existing order. The court reasoned that UIFSA aims to prevent multiple conflicting orders by requiring modification petitions to be filed in a state with personal jurisdiction over the respondent where the statutory conditions for registration and modification are satisfied, placing the burden on the party seeking modification.

family lawprocedure