Danilo Augusto Feliciano v. Susan Hutson, in Her Official Capacity as Orleans Parish Sheriff and Nancy Ruth Landry, in Her Official Capacity as Louisiana Secretary of State, 414 So.3d 1261

Danilo Augusto Feliciano filed a petition contesting the results of a local proposition election held in Orleans Parish on May 3, 2025.
The district court held a trial on June 12, 2025, and rendered a written judgment dismissing Feliciano’s claims later that day at 3:52 p.m.
Feliciano attempted to appeal by filing a notice of appeal at 3:44 p.m. on June 13, 2025, and posted the required appeal bond at 4:13 p.m.—21 minutes past the statutory deadline of 24 hours after judgment.
Defendants argued that the appeal was not timely perfected under La. R.S. 18:1409(D), which requires both the order of appeal and bond to be filed within 24 hours.
Feliciano did not respond to the motions to dismiss or provide evidence to counter the factual record regarding the late bond posting.
The appellate court reviewed the record and dismissed the appeal as untimely.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Feliciano perfected his appeal within the 24-hour statutory deadline for election contests	No specific argument provided; attempted to appeal	Bond posted past deadline, failing strict statutory requirement	Appeal dismissed
Whether the 24-hour deadline for both notice and bond is jurisdictional	Implied compliance (by filing)	Strict construction; any delay strips court of jurisdiction	Statute is mandatory

Dumas v. Jetson, 446 So.2d 747 (La. App. 1st Cir. 1983) (Appeal of election matter dismissed where bond was posted minutes late; strict compliance required)
Cornelius v. Greggs, 329 So.3d 314 (La. App. 1st Cir. 2021) (Appellate court lacks jurisdiction if appeal not timely perfected in election contest)
Sens v. Plaisance, 365 So.3d 17 (La. App. 4th Cir. 2020) (Confirming jurisdictional and mandatory nature of statutory timelines in election appeals)
Plaquemines Par. Council v. Petrovich, 662 So.2d 542 (La. App. 4th Cir. 1995) (Election statutes must be strictly construed and enforced)