Board of Ethics In re Savoie

224 So. 3d 1246, 2017 La.App. 1 Cir. 0077, 2017 WL 3382689, 2017 La. App. LEXIS 1448
CourtLouisiana Court of Appeal
DecidedAugust 7, 2017
Docket2017 CW 0077
StatusPublished
Cited by3 cases

This text of 224 So. 3d 1246 (Board of Ethics In re Savoie) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Board of Ethics In re Savoie, 224 So. 3d 1246, 2017 La.App. 1 Cir. 0077, 2017 WL 3382689, 2017 La. App. LEXIS 1448 (La. Ct. App. 2017).

Opinion

PER CURIAM

|2The relators, an engineer and his engineering firm, seek supervisory review .of the denial of their motion for summary judgment filed with the Louisiana Ethics Adjudicatory Board. Concluding that the relators’ remedy is not a supervisory writ, but an appeal as directed in La. R.S. 42:1142, we grant the writ for the limited purpose of remanding this matter to the Louisiana Ethics Adjudicatory Board with instruction to grant relators an ■ appeal.

PERTINENT FACTS AND PROCEDURAL HISTORY

In November 2015 the Louisiana Board of Ethics (Ethics. Board) voted to file charges against the relators, C.J. Savoie Consulting Engineers, Inc. and Clarence Savoie, II (sometimes collectively, Savoie Engineers), with the Louisiana Ethics Adjudicatory Board (EAB), the administrative body charged with conducting a hearing on the charges. The Ethics Board charged that .Savoie Engineers violated conflict of interest laws while serving as Parish Engineer for St. John the Baptist Parish (sometimes, St. John .Parish). Particularly, the Ethics Board charged that Savoie Engineers, violated La. R.S. 42:1112(A) and La. R.S. 42:1113(A)(l)(a)1 in that Savoie was a “public employee” as defined in La. R.S. 42:1102(18).2

[1248]*1248Un June 2016 Savoie Engineers filed a “Motion and Memorandum in Support of a Summary Judgment” as allowed under Louisiana Administrative Code (LAC) § 52:1.1102 as a prehearing motion in the proceeding begun by the Ethics Board.3 Primarily, Savoie Engineers alleged that they are not public employees and that they were an independent contractor working under contracts for professional services. The Ethics Board opposed the motion.

The motion for summary judgment came for hearing before the EAB on August 4, 2016. The EAB took the motion under advisement, and in November 2016, the EAB rendered and transmitted a written “Order Denying Motion for Summary Judgment.”

On November 29, Savoie Engineers timely filed a notice of intent to file supervisory writs. The EAB set a return date of January 20, 2017. Savoie REngineers timely filed their writ application in which they raise three assignments of error:

1.The EAB erred as a matter of law when it held that the [Ethics Board’s] conclusory evidence contradicted Sa-voie’s affidavit evidence that certain services provided by Savoie to St. John Parish are not “governmental functions” that St. John Parish is required by law to provide for the benefit of the public.
2. The EAB erred as a matter of law when it held that the [Ethics Board’s] conclusory evidence contradicted Sa-voie’s affidavit evidence that Savoie did not provide professional engineering services under the “supervision or authority” of elected officials or other employees of St. John Parish.
3. The EAB erred as a matter of law when it held that the [Ethics Board’s] conclusory evidence contradicted Sa-voie’s affidavit evidence that Savoie did not perform “governmental functions” that the Public Bid Law requires St. John Parish to perform for the benefit of the public.

DISCUSSION

Appellate courts have the duty to examine subject matter jurisdiction sua sponte, even when the parties do not raise the issue. McGehee v. City/Parish of East Baton Rouge, 00-1058 (La. App. 1 [1249]*1249Cir. 9/12/01), 809 So.2d 258, 260. Here, both parties argue that the Louisiana Code of Civil Procedure governs the review of the motion for summary judgment at issue. EAB decisions are reviewed in accordance with the Louisiana Administrative Procedure Act (LAPA). “The LAPA was not intended to supersede the more specific provisions of other administrative acts[.]” Metro Riverboat Associates, Inc. v. Louisiana Gaming Control Bd., 01-0185 (La. 10/16/01), 797 So.2d 656, 662; Corbello v. Sutton, 446 So.2d 301, 303 (La. 1984). “Rather, it was intended to create procedures in those instances where none exist.” Metro Riverboat, 797 So.2d at 662.

However, Part III of Chapter 15 of Title 42 of the Louisiana general statutes, La. R.S. 42:1132 et seq., the Code of Governmental Ethics, set out the specific provisions that govern the Ethics Board and the EAB. Particularly, La. R.S. 42:1142, entitled “Appeals,” governs review of actions taken by the EAB. This | (¡statute was amended by Acts 2012, No. 607, § 1, eff. June 7, 2012, to provide, in pertinent part, as follows:

A. (1) Whenever action is taken against any public servant or person by order of the Board of Ethics, or panel thereof, or by a final decision of the Ethics Adjudicatory Board, or by an agency head by order of the Board of Ethics, or panel thereof, or by a final decision of the Ethics Adjudicatory Board, or whenever any public servant or person is aggrieved by any action taken by the Board of Ethics, or panel thereof, or the Ethics Adjudicatory Board, he may appeal to the Court of Appeal, First Circuit. (Emphasis added.)

While this statute does not specifically address preliminary, procedural, or intermediate actions, the version of the statute immediately preceding did. Acts 2008, 1st Ex. Sess. No. 24, § 1, eff. March 14, 2008, which is no longer in effect, provided, in pertinent part, as follows:

A. Whenever action is taken against any public servant or person by the board or panel or by an agency head by order of the board or panel, or whenever any public servant or person is aggrieved by any action taken by the board or panel, he may appeal therefrom to the Court of Appeal, First Circuit, if application to the board is made within thirty days after the decision of the board becomes final. Any refusal by the board or panel to issue a declaratory opinion or any preliminary, procedural, or intermediate action or ruling by the board or panel is subject to the supervisory jurisdiction of the appellate court as provided by Article V, Section 10 of the Constitution of Louisiana. The Court of Appeal, First Circuit, shall promulgate rules of procedure to be followed in taking and lodging such appeals. (Emphasis added.)

The language of this prior version appears to conflate appellate and supervisory jurisdiction. Even so, it arguably afforded supervisory review of preliminary or intermediate actions, which would normally include a ruling that denies a motion for summary judgment.

In any event, the present version of La. R.S. 42:1142 provides that when any person is aggrieved by any action, he may appeal to this court. “The legislature is presumed to have enacted an article or statute in light of the preceding law involving the same subject matter and court decisions construing those articles or statutes, and where the new article or statute is worded differently from the preceding law, the legislature is presumed to have intended to change the law.” La. RR.S. 24:177(C). Here, the current version of La. R.S. 42:1142 removes all reference to supervisory review of preliminary’, procedur[1250]*1250al, or intermediate actions by the EAB and has expanded the right of appeal. ■

As to which Ethics Board or EAB “actions” are appealable under the current version of La. R.S. 42:1142(A), the Code of Governmental Ethics at La.' R.S. 42:1102(l)(a) provides a pertinent definition for an “Action of a governmental entity,” 4 as follows:

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224 So. 3d 1246, 2017 La.App. 1 Cir. 0077, 2017 WL 3382689, 2017 La. App. LEXIS 1448, Counsel Stack Legal Research, https://law.counselstack.com/opinion/board-of-ethics-in-re-savoie-lactapp-2017.