Paul N. Sens v. Kenneth Michael Plaisance and the Honorable Arthur Morrell, 365 So.3d 17

Paul N. Sens filed a Petition Objecting to Candidacy (July 30, 2020), alleging Kenneth M. Plaisance falsely certified he filed state income tax returns for the prior five years.
The matter proceeded to trial on August 3, 2020; Plaisance did not appear at trial.
The trial court signed and issued a judgment disqualifying Plaisance on August 3, 2020 at 3:20 p.m., and a notice of judgment was issued the same day.
Louisiana law (La. R.S. 18:1409(D)) requires obtaining an order of appeal and posting an appeal bond within 24 hours after judgment in candidacy-objecting suits.
Plaisance filed a motion for appeal on August 10, 2020 and the record was lodged August 12, 2020; he did not obtain an order of appeal or post bond within 24 hours of the judgment.
The Fourth Circuit dismissed the appeal for lack of jurisdiction as untimely under La. R.S. 18:1409(D).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Plaisance timely perfected an appeal under La. R.S. 18:1409(D)	Sens argued the appeal was untimely because no order of appeal or bond was filed within 24 hours	Plaisance sought review by filing a motion for appeal on Aug. 10, arguing for appellate consideration	Court held appeal was untimely; appellant failed to obtain order/post bond within 24 hours, so appellate court lacked jurisdiction
Whether the 24‑hour perfection requirement can be waived/extended	Sens relied on precedent that the short deadline protects the electorate and cannot be waived	Plaisance implicitly asked court to consider his later-filed appeal despite the statutory deadline	Court held the 24‑hour deadline is strict and not waivable; requirements must be met to confer jurisdiction

Schwarzenberger v. Louisiana State Univ. Health Sciences Ctr.-New Orleans, 263 So.3d 449 (La. App. 4 Cir. 2019) (appellate courts must sua sponte assess jurisdiction)
Joseph v. Egan Health Care Corp., 273 So.3d 459 (La. App. 5 Cir. 2019) (absence of a timely appeal divests appellate court of jurisdiction)
Board of Ethics v. Jones, 280 So.3d 242 (La. App. 3 Cir. 2019) (24‑hour appeal period is for expedited treatment and cannot be modified)
Dumas v. Jetson, 445 So.2d 424 (La. 1984) (short appellate deadlines reflect need for expedited handling)
Plaquemines Parish Council v. Petrovich, 662 So.2d 542 (La. App. 4 Cir. 1995) (timely deadlines in election‑related matters cannot be waived)
Tennebaum v. Lecompte, 173 So.3d 1185 (La. App. 4 Cir. 2015) (untimely motion for appeal deprives appellate court of jurisdiction)