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Todd Huval and Chad Boyer v. State of Louisiana Through the Department of Public Safety and Corrections, Office of State Police, Master Trooper Hal Hutchinson, Individually, and in His Official Capacity as an Employee of the Office of State Police, Lieutenant Rhett Trahan, Individually, and in His Official Capacity as an Employee of the Office of State Police, Investigator Buzzy Trahan, Individually, and in His Official Capacity as an Employee of the Office of State Police, Lieutenant Kevin Devall, Individually, and in His Official Capacity as an Employee of the Office of State Police, Investigator Bart Morris, Individually, and in His Official Capacity as an Employee of the Office of State Police, Investigator Hampton Guillory, Individually, and in His Official Capacity as an Employee of the Office of State Police, and Lt. Colonel Stanley Griffin, Individually, and in His Official Capacity as an Employee of the Office of State Police
222 So. 3d 665
| La. | 2017
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Background

  • Huval and Boyer, former Louisiana State Troopers, were terminated in 2007 following an internal investigation alleging they disclosed confidential information.
  • They appealed to the State Police Commission, which reversed the terminations and ordered suspensions and back pay; the State appealed and the Court of Appeal reinstated Huval's termination and affirmed Boyer’s suspension.
  • Plaintiffs filed tort claims in 2008 in 19th JDC seeking damages for wrongful termination, defamation, malicious prosecution, and intentional infliction of emotional distress, alleging State Police presented "fabricated" findings to the Lafayette DA and sought a grand jury.
  • Defendants moved to dismiss for lack of subject-matter jurisdiction, arguing Article X, § 50 of the Louisiana Constitution grants the State Police Commission exclusive jurisdiction over removal and disciplinary cases and plaintiffs’ suit is essentially an employment/disciplinary challenge.
  • Plaintiffs argued the district court has original jurisdiction over tort claims under Article V, § 16 and that the Commission cannot award tort damages; they maintained claims transcend purely disciplinary review.
  • The trial court and the court of appeal (2–1) overruled the exception; the Louisiana Supreme Court granted certiorari and affirmed that the district court has subject-matter jurisdiction over these tort claims.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether district court has SMJ over tort claims arising from disciplinary/removal proceedings Tort claims (defamation, malicious prosecution, IIED) are separate civil claims; Commission lacks power to award tort damages, so district court has SMJ under Art. V, §16 Art. X, §50 gives the State Police Commission exclusive power to hear and decide all removal/disciplinary cases; plaintiffs' tort suit is inextricably linked to disciplinary action and thus outside district court SMJ District court has original jurisdiction over the tort claims; affirmed lower courts’ ruling overruling exception of lack of SMJ

Key Cases Cited

  • Reimer v. Medical Center of Louisiana at New Orleans, 688 So.2d 165 (La. App. 4th Cir. 1997) (held civil court lacked SMJ over claims entwined with civil service disciplinary review; Commission can provide back pay but not all tort relief)
  • Mensman v. Dep’t of Pub. Safety & Corrs., 671 So.2d 319 (La. 1996) (State Police Commission’s authority to hear and decide is analogous to Civil Service Commission)
  • Landrum v. Board of Commissioners of the Orleans Levee District, 685 So.2d 382 (La. App. 4th Cir. 1996) (district court had SMJ where plaintiff’s claims were not removals or suspensions and thus not within civil service exclusivity)
  • Myers v. Ivey, 635 So.2d 632 (La. App. 3d Cir. 1994) (held district court lacked SMJ when plaintiff’s tort claim impermissibly sought to circumvent exclusive civil service jurisdiction)
  • Louisiana Dept. of Agriculture & Forestry v. Sumrall, 728 So.2d 1254 (La. 1999) (explained limits of Civil Service Commission jurisdiction and affirmed district courts as forum for claims outside commission’s constitutional scope)
  • Wooley v. State Farm Fire & Cas. Ins. Co., 893 So.2d 746 (La. 2005) (discussed Article I, §22 access to courts and protection against unwarranted governmental action)
Read the full case

Case Details

Case Name: Todd Huval and Chad Boyer v. State of Louisiana Through the Department of Public Safety and Corrections, Office of State Police, Master Trooper Hal Hutchinson, Individually, and in His Official Capacity as an Employee of the Office of State Police, Lieutenant Rhett Trahan, Individually, and in His Official Capacity as an Employee of the Office of State Police, Investigator Buzzy Trahan, Individually, and in His Official Capacity as an Employee of the Office of State Police, Lieutenant Kevin Devall, Individually, and in His Official Capacity as an Employee of the Office of State Police, Investigator Bart Morris, Individually, and in His Official Capacity as an Employee of the Office of State Police, Investigator Hampton Guillory, Individually, and in His Official Capacity as an Employee of the Office of State Police, and Lt. Colonel Stanley Griffin, Individually, and in His Official Capacity as an Employee of the Office of State Police
Court Name: Supreme Court of Louisiana
Date Published: May 3, 2017
Citation: 222 So. 3d 665
Docket Number: 2016-CC-1857
Court Abbreviation: La.