State of Louisiana vs. Messiah Owney, 2025-KK-01398

Seventeen-year-old Messiah Owney was arrested on multiple violent felony charges after a hearing officer signed an arrest warrant and related search warrants under Orleans Parish Juvenile Court Local Rule 41. 1
Owney moved to suppress, arguing the hearing officer lacked statutory authority to issue the warrants, and the trial court initially agreed before reversing and denying suppression. 2
The Fourth Circuit denied writs, and this Court granted review on the hearing officer’s warrant authority and the validity of the local rule. 3
The majority held that Local Rule 41 §12(B) and (E) conflict with the Children’s Code, Code of Criminal Procedure, and Louisiana Constitution because warrant authority is reserved to judges and magistrates. 4
The Court also held that warrants issued before this decision remain valid because the hearing officer acted as a de facto officer under color of authority. 5

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can juvenile hearing officers issue arrest and search warrants under local rule? 6	Owney said statutes reserve warrant authority to judges or magistrates.	The State said Local Rule 41 authorized the hearing officer.	No; the local rule is null and void. 7
Are warrants already issued by the hearing officer invalid? 8	Owney argued the invalid rule voided the warrants and required suppression.	The State invoked the de facto officer doctrine.	No; the warrants remain valid and suppression is unwarranted. 9

Trahan v. Petroleum Cas. Co., 200 So. 2d 6 (La. 1967) (local court rules cannot conflict with legislation 10)
Jefferson v. Jefferson, 153 So. 2d 368 (La. 1963) (rules of court have the force and effect of law unless conflicting with statute 11)
Rodrigue v. Rodrigue, 591 So. 2d 1171 (La. 1992) (legislation controls when local rules conflict and conflicting rules are void 12)
State v. Cooper, 50 So. 3d 115 (La. 2010) (when local rules conflict with legislation, the legislation controls 13)
Louisiana State Bar Ass'n v. Connolly, 9 So. 2d 582 (La. 1942) (courts may adopt reasonable rules only if they do not contravene statutes or the constitution 14)
Krielow v. Louisiana Dep’t of Agric. & Forestry, 125 So. 3d 384 (La. 2013) (the legislature holds the state’s lawmaking power 15)
State v. Umezulike, 866 So. 2d 794 (La. 2004) (a legislatively authorized commissioner could constitutionally issue search warrants 16)
O’Reilly v. Louisiana State Bd. of Ethics, 785 So. 2d 768 (La. 2001) (de facto officer doctrine validates acts performed under color of authority 17)
State v. Stripling, 354 So. 2d 1297 (La. 1978) (acts of a de facto officer are valid against collateral attack 18)