Thebeau v. Smith, 148 So. 3d 233

Smith filed a notice of candidacy for mayor of Springhill on August 22, 2014 listing a Springhill address.
Thebeau contested Smith’s qualifications, alleging Smith was not domiciled in Springhill for the prior year.
Evidence showed Smith had long-standing ties to Shongaloo, including residency, voter registration, banking, and employment documents.
The trial court heard testimony and documents indicating Smith primarily resided in Shongaloo, with some time at Springhill.
The trial court concluded Smith was not domiciled in Springhill for the required year and disqualified him as a candidate.
The appellate court affirmed, adopting the trial court’s domicile findings and rejecting Smith’s arguments about boundaries and qualification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Thebeau prove Smith failed to meet the domicile requirement?	Thebeau: Smith lacked Springhill domicile for 12 months prior.	Smith: domicile was in Springhill; evidence shows residence there.	Yes; Smith was not domiciled in Springhill for the year prior.
Was Smith eligible to vote in Springhill before his address change?	Thebeau: Smith could not vote in Springhill during the period.	Smith: no explicit evidence of ineligibility to vote before change.	No; evidence supported ineligibility to vote in Springhill before change.
Did the trial court err in considering domicile proof despite geographic boundaries?	Thebeau: boundaries must be established; otherwise relevant.	Smith: boundaries unnecessary; focus on domicile for eligibility.	No error; evidence supported lack of Springhill domicile.

Landiak v. Richmond, 899 So.2d 535 (La. 2005) (domicile requires residence plus intent; multiple residences possible but one domicile)
Morton v. Hicks, 74 So.3d 268 (La. App.2d Cir. 2011) (burden-shifting in election challenges; prescribed approach to prima facie case)
Russell v. Goldsby, 780 So.2d 1048 (La. 2000) (residence vs. domicile; intent to change domicile; evaluation of credibility)