Jack C. Watson

This workers' compensation case involved claimant Harold J. Charles, who alleged head and back injuries from an unwitnessed fall at his welding job and sought benefits including reimbursement for mental health treatment allegedly caused by the physical injury. The hearing officer awarded medical expenses for psychological care plus penalties and attorney fees after finding the mental issues stemmed from the accident, a decision affirmed in part on appeal. The Louisiana Supreme Court reversed those portions of the judgment, holding that Charles failed to prove a compensable mental injury by clear and convincing evidence under the statute, which requires diagnosis by a licensed psychiatrist or psychologist meeting DSM criteria. Multiple evaluations indicated malingering rather than a qualifying mental condition, and no qualifying expert testimony supported the claim. As a result, the employer was not liable for the mental health expenses or penalties for refusing payment.

labor & employment

This case was a criminal matter in Louisiana involving defendants Sedric C. Hampton, Billy Gene Abney, and Bobby L. Perry. The Louisiana Supreme Court reviewed an application for relief from a lower court decision. The court issued a one-word ruling of denied. No additional reasoning or explanation was provided in the opinion.

criminal law

This case involves the direct appeal of Lawson Eugene Strickland's convictions for first-degree murder, armed robbery, and conspiracy to commit armed robbery, along with his death sentence, stemming from the 1992 shooting death of Jesse Pinsonneault during a robbery of bank deposit bags outside a Louisiana bank. A jury found Strickland guilty and recommended the death penalty based on the aggravating factor that the murder occurred during an armed robbery. The Louisiana Supreme Court affirmed the convictions after reviewing multiple assignments of error, including claims related to joinder of offenses and other trial issues. It conditionally affirmed the death sentence but remanded the case for an evidentiary hearing to address Strickland's claim of ineffective assistance of counsel during the penalty phase, reserving his right to appeal any adverse ruling on that issue.

criminal lawprocedure

The case concerned a video gaming licensee who sought to contribute to an advertising fund supporting video poker and challenged Louisiana Revised Statute 27:13(C)(6), which barred gaming licensees, permittees, and related parties from making contributions or expenditures to any candidate or committee. The trial court declared the statute unconstitutional to the extent it restricted contributions to committees advocating for or against ballot issues or propositions, and issued a preliminary injunction. On direct appeal, the Louisiana Supreme Court applied strict scrutiny to the First Amendment implications of the contribution ban, examined definitions of committees under campaign finance law, and reviewed precedents distinguishing candidate contributions from independent issue advocacy.

free speechelectionsbusiness & regulatory

This case arose from a 1991 highway accident on I-10 in which Embry Teel suffered severe injuries after a vehicle hydroplaned on accumulated water, spun out of control, and struck him while he was assisting another driver. The Teels sued the Louisiana Department of Transportation and Development (DOTD) alleging both negligence and strict liability under Civil Code article 2317 for failing to maintain the roadway and warn of the hazard. The trial court allocated 50% fault to the DOTD and awarded damages, but only after declaring R.S. 9:2800 unconstitutional on the ground that its notice requirement for public-entity strict liability constituted an impermissible vestige of sovereign immunity under the state constitution. The Louisiana Supreme Court vacated the trial court's constitutional ruling and remanded the case, holding that a determination of the statute's validity was unnecessary because DOTD liability could be assessed under negligence principles without reaching strict liability. The Court noted that related issues such as fault allocation and damages were not addressed in this appeal.

torts & liabilityprocedure

The case involved a dispute over whether a statute on the time limits for filing certain claims applied retroactively, arising from an exception of prescription that the trial court had sustained but the court of appeal overruled before remanding for trial on the remaining issues. The Louisiana Supreme Court denied the writ application seeking review of that appellate decision. In a concurring opinion, Justice Lemmon explained that the denial carries no res judicata effect on the prescription question because the judgment was interlocutory rather than a final determination of the merits in whole or in part, and the court routinely declines supervisory review of partial judgments that remand for trial.

procedure

The case White v. City of Baker through Baker City Police Department was a lawsuit filed by Reina Ann White individually and on behalf of her minor son against the city police department. The Louisiana Supreme Court denied the writ application for review of the lower court's ruling. The court's order provided no substantive reasoning or discussion of the underlying claims, simply stating the denial with a notation that one justice would have granted the writ.

torts & liabilityprocedurecivil rights

The consolidated cases of LeCroy v. Brand Scaffold Building, Inc. and Bennett v. Brand Scaffold Building, Inc. involved claims by the named plaintiffs against the scaffold company. The Supreme Court of Louisiana considered writ applications or similar requests for review in these matters. The court issued a decision of "Denied," declining to grant the requested relief. One justice was noted as not participating in the panel.

procedure

The case of Steadman v. Georgia-Pacific Corp. involved an appeal or writ application filed by Darwin Steadman against the Georgia-Pacific Corporation in the Louisiana court system. The Louisiana Supreme Court issued a brief order denying the writ without further elaboration or a full opinion. One justice indicated a preference to grant the writ, while another was not participating in the panel. The decision effectively upheld the lower court's ruling by declining to review it. No substantive facts or legal issues from the underlying dispute were addressed in the court's order.

procedure

The case Busby v. St. Paul Ins. Co. involved a dispute with an insurance company and related parties that reached the Supreme Court of Louisiana through a writ application. The court denied the writ without elaboration. One justice indicated they would have granted the writ, while another was not on the panel.

proceduretorts & liability

The case Adams v. City of Baton Rouge involved a lawsuit filed by Thomas and Nancy Adams, individually and on behalf of Jason Adams, against the City of Baton Rouge, the Parish of East Baton Rouge, the State of Louisiana, and the DOTD. The Louisiana Supreme Court denied the application for a writ in this matter. This denial means the court declined to review or overturn the lower court's ruling. One justice noted he would have granted the writ, while another was not on the panel.

torts & liabilityprocedure

This case involved a dispute between William Blanchard and other plaintiffs against the City Parish of East Baton Rouge, Louisiana. The Louisiana Supreme Court denied the writ application seeking review of a lower court decision. One justice indicated he would grant the writ, while another would have granted review specifically on the constitutional issue raised.

procedure

The case involved a dispute between the law firm Benton, Benton and Benton and the Louisiana Public Facilities Authority along with other defendants. The Louisiana Supreme Court denied the writ application, thereby declining to review the lower court's decision. One justice noted a preference to grant the writ, but the majority provided no further reasoning in the opinion.

procedure

This case involved a dispute over whether a tenant's unrecorded lease renewal was binding on a subsequent purchaser of the property, leading to eviction proceedings and a declaratory judgment action. The Louisiana Supreme Court held that the prior final judgment in the eviction suit, which determined that the purchaser was not bound by the unrecorded renewal, precluded relitigation of the same issue in the declaratory judgment action under the doctrine of res judicata. The court reasoned that once a judgment becomes final and definitive after denial of certiorari, it acquires the authority of the thing adjudged, barring subsequent modification by the appellate court in a related action arising from the same transaction. The court of appeal had erroneously applied the discretionary law of the case doctrine instead of res judicata to allow reconsideration of the issue.

propertyprocedure

This case involved a wrongful death lawsuit filed after Alvin Archon was killed in 1989 when his logging truck was struck by a train at the Van-Ply railroad crossing in Louisiana, which lacked active warning signals despite prior accidents and heavy traffic. The trial court allocated fault among the railroad, Archon, the DOTD, and the local police jury, awarding damages to Archon's family that were reduced for his comparative fault. On rehearing, the Louisiana Supreme Court affirmed the judgment, holding the DOTD 22% at fault. The court reasoned that the DOTD assumed a duty to upgrade the crossing with flashing lights and gates when its engineer committed to the project in a 1983 letter and ordered a site survey, but negligently failed to include the signals in the subsequent project notice, breaching that duty and contributing to the accident.

torts & liability

The case concerned whether multiple defendants in a Louisiana criminal prosecution should be tried jointly or severed. The Louisiana Supreme Court ordered severance of the defendants. The core reasoning was that prejudice can arise in joint trials when evidence inadmissible against one defendant, such as incriminating statements by a nontestifying codefendant, is introduced against another. Such statements are presumptively unreliable under the Confrontation Clause, even if the defendant has made an interlocking statement, based on U.S. Supreme Court precedents like Bruton, Lee, and Cruz.

criminal lawprocedure

The case involved two consolidated lawsuits by Allen Begnaud and Linda Easley against the Louisiana Department of Transportation and Development and related parties, arising from incidents on state highways. The Louisiana Supreme Court denied the writ application seeking review of the lower court proceedings. One justice indicated they would have granted the writ, while another was recused from the panel. The opinion provided no further explanation or analysis beyond the denial.

torts & liability

The case Biggs v. Prewitt involved claims by Donald and Diette Biggs along with Allstate Insurance Company against John D. Prewitt Jr. and Louisiana Indemnity Insurance Company, apparently arising from an underlying dispute over liability and insurance coverage. The Louisiana Supreme Court denied the writ application in a brief order without further explanation. This denial means the Court declined to review or disturb the lower court's decision, allowing it to remain in effect. No panel participation by Justice Watson was noted in the order.

torts & liabilityprocedure

This case arose from a car accident at an intersection with a malfunctioning traffic signal showing green to both drivers, injuring a passenger and another motorist. Plaintiffs sued the state DOTD and DPSC alleging negligence and strict liability, but the trial court dismissed the claims against DOTD for failure to prove actual or constructive notice of the defect under LSA-R.S. 9:2800 and found no negligence by DPSC. The court of appeal declared the notice statute unconstitutional as conflicting with the state constitution's waiver of sovereign immunity, then held DOTD strictly liable after reviewing the record de novo. The Louisiana Supreme Court vacated the unconstitutionality ruling because it was unnecessary to decide the case and remanded without addressing other issues.

torts & liabilityprocedure

In State v. Duhon, two defendants on supervised probation for controlled substance possession and forgery contested the validity of summonses for probation revocation hearings, claiming the probation officers' affidavits failed to meet the requirements of a sworn accusation of crime under La.C.Cr.P. art. 385. The Louisiana Supreme Court affirmed the trial courts' denial of the defendants' motions to quash, ruling that the documents were legally sufficient to initiate revocation proceedings. The court reasoned that probation revocation is a distinct post-conviction process separate from criminal prosecutions, so the affidavit definition in art. 385 does not apply, and the sworn statements detailing the specific violations adequately satisfied due process notice requirements under Morrissey v. Brewer and Gagnon v. Scarpelli.

criminal lawprocedure