421 So.3d 585
La. Ct. App.2025Background
- Governor proclaimed a special election for the 19th Judicial District Division O to fill a vacancy, setting a primary and general election and dates for qualifying.
- Act 243 (June 11, 2025) changed election boundaries in East Baton Rouge Parish, repealing prior Election Section I boundaries, effective upon governor's signature.
- Plaintiffs allege 1,781 registered voters were disenfranchised by removal from old to new Election Section I, affecting candidate qualification.
- Act 243’s boundary changes occurred before candidate qualification, allegedly forcing new boundaries to govern the election.
- Plaintiffs sought a writ of mandamus to compel compliance with the proclamation using only February 28, 2025 Election Section I boundaries.
- District court denied mandamus; plaintiffs appealed to challenge the district court's ruling on ministerial vs. discretionary duties.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandamus lies to compel compliance with proclamation when boundaries changed | Johnson argues ministerial duty to follow proclamation boundaries | Landry/Raborn argue boundary changes are discretionary after Act 243 | No mandamus; boundary changes discretionary, not ministerial |
| Whether registrar’s ministerial duty required applying old Election Section I boundaries | Voters should vote as per February 28, 2025 boundaries | Registrar complied by assigning voters to new Election Section O | Registrar’s duty was ministerial; acted within new boundaries; mandamus denied |
| Whether Secretary of State had any ministerial duty to enforce proclamation | SOS must ensure compliance with proclamation | No explicit ministerial duty identified for SOS | No ministerial duty on SOS; mandamus not warranted |
Key Cases Cited
- Texas Brine Co., LLC v. Naquin, 340 So.3d 720 (La. 2020) (mandamus limited to ministerial duties; discretion invalidates mandamus)
- Hoag v. State, 889 So.2d 1019 (La. 2004) (clarifies ministerial vs discretionary duties in mandamus)
- Lowther v. Town of Bastrop, 320 So.3d 369 (La. 2021) (discretion and evidence evaluation precludes mandamus)
- Zillow, Inc. v. Gardner, 341 So.3d 765 (La. App. 1st Cir.) (statutory interpretation on ministerial duties)