Daryl G. Purpera, in his official capacity as Louisiana Legislative Auditor and as Chairman of the Task Force on Coordination of Medicaid Fraud Detection and Prevention Initiatives v. Kimberly Lewis Robinson, in her official capacity as Secretary of Louisiana Department of Revenue

CourtLouisiana Court of Appeal
DecidedFebruary 19, 2021
Docket2020CA0815
StatusUnknown

This text of Daryl G. Purpera, in his official capacity as Louisiana Legislative Auditor and as Chairman of the Task Force on Coordination of Medicaid Fraud Detection and Prevention Initiatives v. Kimberly Lewis Robinson, in her official capacity as Secretary of Louisiana Department of Revenue (Daryl G. Purpera, in his official capacity as Louisiana Legislative Auditor and as Chairman of the Task Force on Coordination of Medicaid Fraud Detection and Prevention Initiatives v. Kimberly Lewis Robinson, in her official capacity as Secretary of Louisiana Department of Revenue) 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.

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Daryl G. Purpera, in his official capacity as Louisiana Legislative Auditor and as Chairman of the Task Force on Coordination of Medicaid Fraud Detection and Prevention Initiatives v. Kimberly Lewis Robinson, in her official capacity as Secretary of Louisiana Department of Revenue, (La. Ct. App. 2021).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL J NV FIRST CIRCUIT

Ca k NO. 2020 CA 0815

DARYL G. PURPERA, IN HIS OFFICIAL CAPACITY AS LOUISIANA LEGISLATIVE AUDITOR AND AS CHAIRMAN OF THE TASK FORCE ON COORDINATION OF MEDICAID FRAUD DETECTION AND PREVENTION INITIATIVES

VERSUS

KIMBERLY LEWIS ROBINSON, IN HER OFFICIAL CAPACITY AS SECRETARY, LOUISIANA DEPARTMENT OF REVENUE

Judgment Rendered: FEB 1 9 2021

On Appeal from the 19th Judicial District Court State of Louisiana, Parish of East Baton Rouge Trial Court No. 682, 726

The Honorable Trudy M. White, Judge Presiding

Antonio C. Ferachi Attorneys for Defendant -Appellee, Shone T. Pierre Kimberly Lewis Robinson, in her Baton Rouge, Louisiana official capacity as Secretary of the Department of Revenue, State of Louisiana

Jenifer Schaye Attorneys for Plaintiff A - ppellant, Angela M. Heath Daryl G. Purpera, in his official Baton Rouge, Louisiana capacity as Legislative Auditor, State of Louisiana

BEFORE: THERIOT, WOLFE, AND RESTER, JJ. WOLFE, J.

This appeal challenges a trial court' s judgment sustaining various exceptions

pled in response to a petition for declaratory judgment. For the reasons that follow,

we affirm.

FACTS AND PROCEDURAL HISTORY

Plaintiff, Daryl G. Purpera, in his official capacity as the Legislative Auditor

for the State of Louisiana (" Auditor"), filed a petition for declaratory judgment

against defendant, Kimberly Lewis Robinson, in her official capacity as Secretary

of the Department of Revenue for the State of Louisiana (" LDR").' The Auditor

sought a declaratory judgment decreeing that the LDR must assist the Auditor in his

financial audit of the Louisiana Department of Health (" LDH"). Specifically, the

Auditor sought a declaration that the LDR could provide certain statistical data

comparing Medicaid recipients' self-reported income to the LDH in 2017 against

the same recipients' self-reported income to the LDR on their 2017 Louisiana tax

returns. After initially reporting the number of 2017 Medicaid recipients who filed

2017 Louisiana tax returns to the Auditor, the LDR declined to provide the

remainder of the requested information. The LDR claimed that the information

sought by the Auditor was confidential and privileged, and not within the scope of

any of the statutory exceptions in La. R.S. 47: 1508 that would allow the LDR to

disclose any information obtained from the LDR' s records.

In response to the Auditor' s petition, the LDR filed exceptions raising the

objections of prematurity, lack of procedural capacity, lack of subject matter

jurisdiction, no cause of action, and lack of standing. The LDR asserted that the

Auditor was not auditing the LDR. Instead, the auditee was the LDH. Thus, the

1 In the original petition, Mr. Purpera filed in his official capacity as Auditor and as Chairman of the Task Force on Coordination of Medicaid Fraud Detection and Prevention Initiatives. Mr.

Purpera later filed a restated and amended petition for declaratory judgment solely in his official capacity as Auditor.

2 LDR maintained that the Auditor had no authority to demand the confidential and

privileged tax information from the 2017 Louisiana tax returns of Medicaid

recipients and the LDR had no duty to comply with the Auditor' s demands. The

LDR also argued that there was no justiciable controversy between the parties and

that the Auditor was merely requesting answers to theoretical questions.

Conversely, the Auditor claimed that the tax information at issue constituted

statistical data sets that did not reveal the identification of the taxpayer and,

accordingly, the information sought was not confidential, pursuant to La. R.S.

47: 1508( B)( 2). Following a hearing, the trial court issued a judgment sustaining the

LDR' s exceptions and declining to exercise jurisdiction " as no justiciable

controversy exists until the [ Auditor] follows the administrative [ subpoena] remedy

outlined in La. R.S. 24: 513( M)( 1)." Therefore, the trial court dismissed the

Auditor' s petition for declaratory judgment and the Auditor appealed.2 LAW AND ANALYSIS

The Auditor argues that the trial court legally erred in sustaining the LDR' s

exceptions and in holding that no justiciable controversy exists that would warrant

declaratory relief until the Auditor follows the administrative subpoena remedy

outlined in the Audit Law. Louisiana Revised Statutes 24: 513( M)( 1) provides that

in the performance of his duties, the "[ Auditor] and the chairman of the Legislative

Audit Advisory Council [" Chairman"] may jointly issue a subpoena ... to compel

the production of any ... documents[.]" The next section, La. R.S. 24: 513( M)(2),

provides that "[ i] f a person refuses to obey a subpoena ..., a judicial district court,

upon joint application by the [ Auditor] and the [ Chairman], may issue to the person

2 The trial court initially issued a defective judgment that resulted in this court' s dismissal of the Auditor' s first appeal. Purpera v. Robinson, 2020- 0092 ( La. App. 1 st Cir. 4/ 28/ 20)( unpublished action). In dismissing the first appeal, this court noted that "[ o] nce a valid final judgment containing appropriate decretal language is signed, any aggrieved party can then seek review of that judgment." The trial court signed an amended judgment on May 5, 2020, which we find has corrected the defect noted in the dismissal of the judgment at issue in the first appeal.

3 an order requiring him to appear before the court to show cause why he should not

be held in contempt for refusal to obey the subpoena." The LDR maintains that the

Audit Law clearly and unambiguously specifies a means to accomplish the Auditor' s

goal of obtaining the desired documents from the LDR. However, because the

Auditor did not pursue that remedy and instead, filed a petition for declaratory relief,

the LDR submits that there is no justiciable controversy for judicial review. We

agree with the LDR that the Auditor lacked standing to bring this action and that

there was no justiciable controversy between the parties. Thus, we pretermit

discussion of the other exceptions ruled on by the trial court.

Without a doubt, for a court to entertain an action for declaratory relief, there

must be a justiciable controversy and the question presented must be real and not

theoretical. American Waste & Pollution Control Co. v. St. Martin Parish Police

Jury, 627 So.2d 158, 162 ( La. 1993). The function of a declaratory judgment is to

establish the rights of the parties or express the opinion of the court on a question of

law without ordering anything to be done. Code v. Department of Public Safety

and Corrections, 2011- 1282 ( La. App. 1st Cir. 10/ 24/ 12), 103 So. 3d 1118, 1126-

27, writ denied, 2012- 2516 ( La. 1/ 23/ 13), 105 So. 3d 59. It is well settled that courts

will not decide abstract, hypothetical or moot controversies, or render advisory

opinions with respect to such controversies. Cat' s Meow, Inc. v. City of New

Orleans, 98- 0601 ( La. 10/ 20/ 98), 720 So. 2d 1186, 1193. A justiciable controversy

involves a dispute where the parties have real adverse interests, and the party seeking

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Daryl G. Purpera, in his official capacity as Louisiana Legislative Auditor and as Chairman of the Task Force on Coordination of Medicaid Fraud Detection and Prevention Initiatives v. Kimberly Lewis Robinson, in her official capacity as Secretary of Louisiana Department of Revenue, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daryl-g-purpera-in-his-official-capacity-as-louisiana-legislative-auditor-lactapp-2021.