John Aaron Duhon v. Lafayette City-Parish Consolidated Government

CourtLouisiana Court of Appeal
DecidedDecember 30, 2005
DocketCA-0005-0657
StatusUnknown

This text of John Aaron Duhon v. Lafayette City-Parish Consolidated Government (John Aaron Duhon v. Lafayette City-Parish Consolidated Government) 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
John Aaron Duhon v. Lafayette City-Parish Consolidated Government, (La. Ct. App. 2005).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL, THIRD CIRCUIT

05-657

JOHN AARON DUHON, ET AL

VERSUS

LAFAYETTE CONSOLIDATED GOVERNMENT

************** APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NUMBER 2004-3599 HONORABLE PATRICK MICHOT, PRESIDING

************* SYLVIA R. COOKS JUDGE **************

Court composed of Sylvia R. Cooks, Michael G. Sullivan, and James T. Genovese, Judges.

REVERSED AND REMANDED.

Hawkins & Villemarette, L.L.C. Scott M. Hawkins Chris Villemarette 102 Asma Boulevard Saloom III, Suite 110 Lafayette, Louisiana 70508 (337) 233-8005 COUNSEL FOR PLAINTIFFS/APPELLANTS: John Aaron Duhon, et al.

Roy, Bivins, Judice, Roberts & Wartelle Patrick M. Wartelle Post Office Drawer Z Lafayette, Louisiana 70502 (337) 233-7430 COUNSEL FOR DEFENDANT/APPELLEE: Lafayette City-Parish Consolidated Government COOKS, Judge.

STATEMENT OF THE CASE

This case arises out of a political dispute between City-Parish Councilman

Lenwood Broussard and Linda Navarre Duhon, one of the thirty-five plaintiffs in this

suit. Mr. Broussard and Mrs. Duhon have traveled a long and litigious road together

beginning in 1999 when Mrs. Duhon was a candidate for the council seat held by Mr.

Broussard. The following is a brief legal history of this dispute.

In September 1999, Mr. Broussard filed an action in district court objecting

to the candidacy of Mrs. Duhon. The issue in that suit was whether Mrs. Duhon was

a resident of Lafayette Parish and, thereby, eligible to run as a candidate for the

Lafayette City-Parish Council in the primary election on October 23, 1999. The

district court found Mrs. Duhon’s residence, located at 101 Adola Road, Maurice,

Louisiana, was within the boundary of Vermilion Parish and, therefore, Mrs. Duhon

was ineligible to run for a seat on the Lafayette City-Parish Council. The trial court

relied on the testimony of the parish engineer for Vermilion Parish, the assistant

director of Public Works for Lafayette Parish and a licensed land surveyor. These

witnesses testified, based on parish maps, that 101 Adola Road was shown to be

located within Vermilion Parish. This court affirmed, specifically leaving open the

question as to the exact location of the boundary between the two parishes. This

court stated:

Defendant also raised the exception of indispensable party arguing that the Lafayette Consolidated Government had an indispensable interest in the establishment of the boundary line between Lafayette and Vermilion Parishes. In the present case the trial court did not establish or change the parish boundary line, it merely made a factual determination based on expert testimony that Ms. Duhon’s home was located in Vermilion Parish.

Broussard v. Duhon, 99-1426, p. 5 (La.App. 3 Cir. 9/21/99), 748 So.2d 14, 16, writ denied, 747 So.2d 1129 (La. 1999).

2 Subsequent to the appellate court decision, the State Tax Commission deleted

John Aaron and Linda Navarre Duhon’s residence from the tax rolls of Lafayette

Parish, indicating on the form the Duhon’s property was located in Vermilion Parish.

In response, Mr. Duhon, along with twenty-four of his neighbors, filed a lawsuit in

the United States District Court for the Western District of Louisiana. Named as

Defendants were members of the Lafayette City-Parish Consolidated Government,

members of the Vermilion Parish Police Jury, the Vermilion and Lafayette Parish tax

assessors and registrars of voters, the State Land Office, the State Attorney General,

and the Louisiana Tax Commissioner. The Plaintiffs asserted federal question

jurisdiction pursuant to 42 U.S.C. § 1983. Specifically, the Plaintiffs alleged the

Defendants violated their constitutional rights under the Fourteenth Amendment’s

Due Process Clause by conspiring to change the boundary line between Lafayette and

Vermilion Parishes, thereby “exiling” them from Lafayette Parish and removing their

names from the tax assessment and voter registration rolls of Lafayette Parish. The

Plaintiffs asserted an Equal Protection violation “in that they are now being treated

as residents of Vermilion Parish because Linda Navarre Duhon exercised her

constitutional right to run for elective office within Lafayette.” Additionally, the

Plaintiffs alleged a violation of their First Amendment “rights to freedom of

association within the political process and the school system of Lafayette Parish.”

The Plaintiffs alleged their “exile” was “for purely political reasons” and was done

“in direct contravention of Louisiana statutes and constitutional provisions which

establish substantive and procedural rights respecting the change of parish

boundaries, and is a response to the qualification of Linda Duhon.” The Plaintiffs

requested injunctive relief and damages and sought to have their names reinstated on

the Lafayette Parish tax assessment and voter registration rolls. The Defendants

3 argued neither the Constitution nor any federal statutes were violated, and therefore,

the federal court lacks subject matter jurisdiction. The federal court agreed and

dismissed the lawsuit, stating:

Plaintiffs’ allegations of constitutional violations of due process, equal protection and freedom of association are without merit. Because the plaintiffs have not alleged specific facts which constitute either a violation of clearly established constitutional rights under current law or under the law as clearly established at the time of the events in question, this Court has no subject matter jurisdiction.

Duhon v. Consolidated Government of Lafayette, et al., Docket No. 00-CV-1690 (W.D.La. 3/27/01).

A judgment was signed in accordance with the decision dismissing with

prejudice the Plaintiffs’ claims under Title 42 §1983 and dismissing without prejudice

the Plaintiffs’ state law claims. The judgment of the federal district court was

affirmed on appeal. Duhon v. Consolidated Government of Lafayette, 31 Fed. Appx.

838, C.A. 5 (La.), 2002, cert. denied, 536 U.S. 940, 122 S.Ct. 2621. Despite the lack

of subject matter jurisdiction, the federal court opinion discussed in detail one of the

issues raised by Plaintiffs, namely whether the Lafayette Consolidated Government

followed the requirements of state law in establishing the boundary. This argument

would be raised later in the Plaintiffs’ state court suit for an injunction and

declaratory judgment.

The Plaintiffs asserted two state statutes were at issue, La.R.S. 33:141 and

La.R.S. 50:221. Louisiana Revised Statutes 33:141 mandates the procedure when a

parish is changing an existing boundary, while Louisiana Revised Statutes 50:221-

224 mandates the procedure when a parish is merely seeking to clarify an already

existing boundary.

Louisiana Revised Statutes 33:141 provides, in relevant part:

Whenever the police jury of any parish passes an ordinance changing a boundary line between it and any adjoining parish, it shall serve the

4 president of the police jury of the adjoining parish with a copy of the ordinance. If the police jury of the second parish concurs in the object and purposes of the ordinance, both police juries shall pass ordinances providing for special elections to be held in both parishes within 60 days from the passage of the ordinances.

Louisiana Revised Statutes 50:221 provides, in relevant part:

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John Aaron Duhon v. Lafayette City-Parish Consolidated Government, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-aaron-duhon-v-lafayette-city-parish-consolidated-government-lactapp-2005.