The Cartesian Company, Inc. and Greg Gachassin v. the Division of Administrative Law Ethics Adjudicatory Board Panel a and the Louisiana Board of Ethics, 371 So.3d 1041

Greg Gachassin was chairman/trustee of the Lafayette Public Trust Financing Authority (LPTFA) and is sole owner/president of Cartesian, a real-estate development company.
In 2009 Cartesian entered into $500,000 project consultant agreements for two affordable-housing projects (Cypress Trails and Villa Gardens) that were under LPTFA/LHA supervision; Gachassin signed/authorized related actions while on the LPTFA board and later resigned.
The Louisiana Board of Ethics (BOE) and the Ethics Adjudicatory Board (EAB) found Gachassin and Cartesian violated La. R.S. 42:1113(B) (prohibiting an appointed member or his entity from bidding on, entering into, or "be[ing] in any way interested in" contracts under the agency’s supervision) and imposed fines/penalties; portions of that decision were affirmed on appeal.
Plaintiffs then filed a declaratory-judgment action challenging the phrase "in any way interested in" as unconstitutionally vague and overbroad; cross-motions for summary judgment followed.
The trial court struck the phrase as unconstitutionally vague and overbroad; BOE appealed directly to the Louisiana Supreme Court.
The Supreme Court held the phrase was not facially overbroad (overbreadth doctrine inapplicable) but was unconstitutionally vague as applied to Plaintiffs and facially vague in all applications; it struck the phrase from La. R.S. 42:1113(B) and severed the remainder of the statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Facial overbreadth of "in any way interested in"	Phrase is unconstitutionally overbroad and could reach protected conduct	No First Amendment interest here; overbreadth doctrine does not apply	Reversed: phrase is not facially overbroad (overbreadth challenge fails)
2) Vagueness as applied to Plaintiffs	Phrase is vague; Murtes controls; Plaintiffs lacked notice what conduct was proscribed	Phrase reasonably read to forbid financial/pecuniary interests; Plaintiffs entered proscribed contract	Affirmed: phrase unconstitutionally vague as applied to Plaintiffs
3) Facial vagueness (all applications)	Phrase lacks any definable standard and thus is void in all applications	Phrase can be reasonably construed to mean a financial interest and harmonized with Ethics Code	Affirmed: phrase unconstitutionally vague on its face; struck from statute
4) Remedy / severability	Strike the offending words and invalidate EAB enforcement	Preserve statute or interpret to save constitutionality	Court struck "or be in any way interested in" and severed remainder; rest of §1113(B) remains valid

Village of Hoffman Estates v. Flipside, Hoffman Estates, Inc., 455 U.S. 489 (1982) (standards for overbreadth and vagueness challenges to regulatory statutes)
Grayned v. City of Rockford, 408 U.S. 104 (1972) (void-for-vagueness due process principles)
State v. Murtes, 94 So.2d 446 (La. 1957) (holding the phrase "in any way interested" unconstitutionally vague in a statutory context)
Carver v. Louisiana Dep’t of Public Safety, 239 So.3d 226 (La. 2018) (presumption of constitutionality and construction to preserve statute)
Sessions v. Dimaya, 584 U.S. _ (2018) (void-for-vagueness doctrine emphasized in the criminal/penal context)
State v. Boyd, 710 So.2d 1074 (La. 1998) (vagueness analysis to be examined in light of facts where First Amendment not implicated)