Devon Energy Production Company, L.P. v. Louisiana Department of Natural Resources and Thomas Harris

Opinion

STATE OF LOUISIANA COURT OF APPEAL, FIRST CIRCUIT

DEVON ENERGY PRODUCTION NO. 2026 CW 0504 COMPANY, L.P.

VERSUS

LOUISIANA DEPARTMENT OF NATURAL RESOURCES AND THOMAS HARRIS, IN HIS OFFICIAL CAPACITY AS SECRETARY OF THE LOUISIANA DEPARTMENT OF NATURAL RESOURCES

JUNE 15, 2026

In Re: Louisiana Department of Natural Resources, applying for supervisory writs, 19th Judicial District Court, Parish of East Baton Rouge, No. 727086.

BEFORE : WOLFE, HESTER, AND BALFOUR, JJ.

WRIT DENIED. The district court’s February 9, 2026 judgment rendered a finding of contempt, but deferred the determination of sanctions. Although La. Code Civ. P. art. 1915(A) (6) provides that a judgment imposing sanctions is an appealable judgment, specification of the sanction imposed is essential before this court can review a contempt finding because the sanction determines whether the contempt is civil or criminal and which burden of proof applies. See Suazo v. Suazo, 2010-0111 (La. App. lst Cir. 6/11/10), 39 So.3d 830, 832. A contempt finding without imposition of sanctions may not be ripe for review on writ application, either. Id. at 833. Once sanctions for the contempt finding are determined, such a judgment will constitute a final, appealable judgment, and relator will be entitled to file a motion for appeal therefrom in accordance with applicable law. See Capital City Press, LLC v. Louisiana State Univ., 2013-1994 (La. 8/28/13), 120 So.3d 250 (“Insofar as relator is aggrieved by the August 14, 2013 judgment imposing sanctions for contempt, it has an adequate remedy by suspensive appeal.”), citing La. Code Civ. P. art. 1915(A) (6).

EW CHH KEB

QURT OF APPEAL, FIRST CIRCUIT

f j A A ye YW, iy “See “east ee TY id’ OF COURT

FOR THE COURT

Sa