Livingston Parish Council on Aging v. Graves, 105 So. 3d 683

In 2003, Livingston Parish established a two-millage property tax approved by voters to fund elderly programs.
In 2004, the Sheriff began collecting the Council’s tax and deducted a 12% commission from ad valorem taxes collected.
In 2010, the Council filed suit seeking return of commissions and prohibition on future commissions from the Council’s millage.
The trial court ruled commissions improper and ordered refunds; the court also barred future commissions on millages for the Council.
The appellate court reversed, holding Act 689 did not repeal the Sheriff’s authority to deduct commissions for post-1977 ad valorem taxes, based on the statutory interplay of 33:1423 and 13:5903.
The Supreme Court held that Act 689 replaced commission-based funding with law enforcement district millages, repealing the Sheriff’s right to deduct commissions from ad valorem taxes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Act 689 repeal the sheriff's ad valorem commission right?	Graves argues the right exists under 33:1423(C) for ad valorem taxes.	Council argues Act 689 replaced funding with district millages and repealed the commission deduction.	statute grants replacement funding; right repealed

Atchafalaya Basin Levee Dist. v. Pecquet, 364 So.2d 610 (La.App. 1 Cir. 1978) (legislative changes to sheriff funding in 689 contextualized)
Fontenot v. Reddell Vidrine Water Dist., 836 So.2d 14 (La. 2003) (statutory interpretation governs intent and context)
Holly & Smith Architects, Inc. v. St. Helena Congregate Facility, Inc., 943 So.2d 1037 (La. 2006) (read statutes in context and harmonize related provisions)
M.J. Farms, Ltd. v. Exxon Mobil Corp., 998 So.2d 16 (La. 2008) (legislative intent evidenced by text and surrounding provisions)
Red Stick Studio Development, L.L.C. v. State ex rel. Dept. of Economic Development, 56 So.3d 181 (La. 2011) (statutory interpretation and legislative intent)