Louisiana Board of Ethics v. Wilson, 161 So. 3d 785

Ralph Wilson, a long‑time Natchitoches Parish School Board member, failed to timely file a Tier 3 personal financial disclosure for 2012 and filed it in November 2013.
The Louisiana Board of Ethics assessed the maximum $1,500 late‑filing penalty in December 2013 and notified Wilson with a 20‑day period to pay, appeal, or request a waiver.
No collection suit or further Board action occurred for several months; Wilson signed his notice of candidacy on August 21, 2014 and qualified the next day.
The Board filed an objection to candidacy on August 29, 2014, alleging Wilson falsely certified on his notice that he owed no outstanding Ethics fines, and sought both enforcement of the penalty and disqualification.
At the September 2, 2014 hearing, Wilson testified (unrebutted) that he believed the fee had been resolved earlier; he did not dispute the amount and was willing to pay.
The trial court ordered Wilson to pay the $1,500 penalty but denied the Board’s objection and refused to disqualify him; the court of appeal affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wilson’s notice contained a false certification that he owed no outstanding Ethics fines	Board: Wilson’s August 21 certification was false because a $1,500 penalty had been assessed and remained unpaid	Wilson: He reasonably believed the matter had been resolved before qualifying; his testimony was uncontested	Court: Trial court reasonably found Wilson rebutted the allegation; certification not proved false for disqualification purposes
Whether a finding of false certification requires mandatory disqualification	Board: If false certification proved, La. R.S. 18:494 mandates disqualification	Wilson: No prima facie case was established; thus mandatory disqualification statute not triggered	Court: Because objection was not sustained (no prima facie case), mandatory disqualification provision did not apply; candidacy allowed

Stobart v. State, Through DOTD, 617 So.2d 880 (appellate review for manifest error)
Rosell v. ESCO, 549 So.2d 840 (manifest error standard)
Mart v. Hill, 505 So.2d 1120 (two‑tier test for reversing fact findings)
Arceneaux v. Domingue, 365 So.2d 1330 (deference to trial court factfinding)
Housley v. Cerise, 579 So.2d 973 (appellate deference despite different inferences)
Canter v. Koehring Co., 283 So.2d 716 (trial court’s advantage in evaluating witnesses)
Russell v. Goldsby, 780 So.2d 1048 (election laws construed to promote, not defeat candidacy)
Pattan v. Fields, 661 So.2d 1320 (doubt on qualifications resolved in favor of candidacy)
Landiak v. Richmond, 899 So.2d 535 (liberal construction for candidates; burden on objector)
State, Bd. of Ethics v. Darby, 937 So.2d 929 (distinguished: different statutes and facts regarding mandatory disqualification)