Hunter Hidalgo, ph.D. v. Board of Supervisors of Louisiana State University and Agricultural and Mechanical College on Behalf of Louisiana State University Health Sciences Center

Dr. Hunter Hidalgo filed a lawsuit against LSU’s Board of Supervisors and several university officials, alleging mishandling of scientific misconduct allegations concerning his PhD thesis.
Hidalgo claimed that LSU’s procedures deviated from policy and federal requirements, breaching obligations and violating his due process rights.
The jury ruled in Hidalgo’s favor, and the trial court ordered that LSU not revoke his PhD, required his re-enrollment in the School of Medicine, and ordered expungement of misconduct findings from his records.
Hidalgo later filed a contempt motion asserting LSU had not properly expunged his records, citing derogatory language in his medical residency application (MSPE).
The trial court held the university and its counsel in contempt, but the finding was suspended pending further compliance and a future hearing.
The university defendants sought rehearing, arguing the contempt finding violated procedural requirements under Louisiana law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court properly follow procedure in holding LSU and its counsel in contempt?	Contempt appropriate due to noncompliance with the court's expungement orders and continued harm to plaintiff.	Contempt invalid because no notice or proper hearing was given as required by La. C.C.P. art. 225.	No; contempt holding vacated for failure to provide required notice and hearing.
Was the misconduct finding a direct or constructive contempt?	Implied ongoing violation was direct and merited immediate sanction.	Asserted conduct was constructive contempt, not direct; thus, required specific procedure.	Court held it was constructive contempt, requiring 48-hour notice and hearing.
Was the suspended contempt judgment nonetheless a final contempt finding?	Court should enforce compliance through contempt, regardless of suspension.	Argued a suspended conviction is still a conviction and thus premature/invalid without due process.	Court agreed: suspension did not cure due process violation.
Should the portion of judgment awarding costs and fees for contempt stand?	Sought attorney's fees and costs for having to enforce court's orders.	Fees/costs based on invalid contempt and should not stand.	Judgment awarding costs and fees also vacated.

Barak v. Saacks, 367 So.3d 656 (La. App. 4 Cir. 2022) (explained trial court discretion in contempt but requirement to adhere to procedural rules)
Davidson v. Castillo, 276 So.3d 1157 (La. App. 2 Cir. 2019) (violation of C.C.P. art. 225 requirements renders contempt finding invalid)
In re T.S., 32 So.3d 1026 (La. App. 2 Cir. 2010) (failure to follow procedural due process in contempt proceedings invalidates judgment)