John Callis v. Greater Alexandria Economic Development Authority

CourtLouisiana Court of Appeal
DecidedApril 16, 2025
DocketCA-0024-0598
StatusUnknown

This text of John Callis v. Greater Alexandria Economic Development Authority (John Callis v. Greater Alexandria Economic Development Authority) 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 Callis v. Greater Alexandria Economic Development Authority, (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

24-598

JOHN CALLIS

VERSUS

GREATER ALEXANDRIA ECONOMIC DEVELOPMENT AUTHORITY, ET AL.

**********

APPEAL FROM THE NINTH JUDICIAL DISTRICT COURT PARISH OF RAPIDES, NO. 279,724 HONORABLE MONIQUE F. RAULS, DISTRICT JUDGE

WILBUR L. STILES JUDGE

Court composed of Elizabeth A. Pickett, Wilbur L. Stiles, and Clayton Davis, Judges.

REVERSED AND RENDERED. Jonathan D. Stokes Jacob R. Joffrion Chadwick, Odom, & Stokes Post Office Box 12114 Alexandria, LA 71303 (318) 445-9899 COUNSEL FOR PLAINTIFF/APPELLEE: John Callis

Allison A. Jones Marcus D. Sandifer Downer, Jones, Marino & Wilhite 401 Market Street, Suite 1250 Shreveport, LA 71101 (318) 213-4444 COUNSEL FOR DEFENDANT/APPELLANT: Angela Varnado

Barbara B. Melton Faircloth Melton Sobel & Bash, LLC 105 Yorktown Drive Alexandria, LA 71303 (318) 619-7755 COUNSEL FOR DEFENDANT: Greater Alexandria Economic Development Authority STILES, Judge.

The trial court issued a declaratory judgment finding that the Greater

Alexandria Economic Development Authority conducted its Monday, February 19,

2024 meeting in violation of the Open Meetings Law and that actions taken at that

meeting were void and without effect. Defendant Angela Varnado, whose

employment contract was approved at that meeting, appeals. For the following

reasons, we reverse and render.

FACTS AND PROCEDURAL HISTORY

Plaintiff John Callis filed the petition for declaratory judgment in stating this

matter, asserting that, in noticing its February 19, 2024 Board Meeting, GAEDA

failed to abide by the twenty-four hour notice requirement of La.R.S. 42:19.

Although GAEDA issued notice of the meeting on Friday, February 16, 2024,

La.R.S. 42:19(A)(1)(b)(i) provides that the twenty-four hour period of the notice

requirement is “exclusive of Saturdays, Sundays, and legal holidays[.]” As pertinent

to this matter, February 19, 2024 was Washington’s Birthday, a date designated a

legal holiday by La.R.S. 1:55(A). Plaintiff thus argued that the date must be excluded

from calculating the notice period of La.R.S. 42:19, and the earliest GAEDA could

have conducted its meeting was Tuesday, February 20, 2024.

Plaintiff sought a declaration that GAEDA issued the notice and conducted

the Board Meeting in violation of the Open Meetings Law, that all actions taken at

the Board Meeting involving the appointment of Ms. Varnado as Executive Director

and the approval of the Executive Director Agreement were void and without effect,

and that Ms. Varnado had no rights in the Agreement due to its nullity. Plaintiff

named GAEDA and Ms. Varnado as defendants. Plaintiff otherwise broadly sought

“any other relief” to which he was “entitled under the law.” GAEDA and Ms. Varnado responded with the filing of an exception of no

cause of action whereby they asserted that there was no violation of the twenty-four

hour notice requirement. Referencing La.R.S. 1:55(B), Defendants pointed out that

Washington’s Birthday was not proclaimed as a day of rest by the governor and was

thus not an “observed” holiday in 2024. Neither did the City of Alexandria recognize

Washington’s Birthday as a legal holiday. Defendants thus maintained that

Washington’s Birthday could not constitute a legal holiday as contemplated by the

Open Meetings Law.

Plaintiff argued in opposition to the exception that February 19, 2024,

Washington’s Birthday, must be considered in computing the twenty-four hour

period of La.R.S. 42:19. He explained that the public policy underlying the Open

Meetings Law ensures that citizens be advised and made aware of the deliberations

and decisions of their public officials. See La.R.S. 42:12. He noted that the Open

Meetings Law is to be construed liberally. Id.

At the hearing on the exception of no cause of action, the parties stipulated to

the pertinent facts, including the timing of the notice, the fact that the Meeting was

conducted, that February 19, 2024 was the third Monday in February and was thus

designated as Washington’s Birthday, and that the governor did not issue a

proclamation regarding the holiday in 2024. The parties also stipulated that, during

the February 19th meeting, the Board approved a compensation package and contract

for Ms. Varnado as permanent Executive Director of GAEDA as set forth in the

Executive Director Agreement.

The trial court denied the exception, ruling from the bench that:

Washington’s Birthday, the - - excuse me, Revised Statute, La.R.S. 1:55(A) lists the legal holidays, and in that statute, Washington’s Birthday is listed as a holiday. So the Court finds that

2 Washington’s Birthday is a legal holiday, and that the Meeting violated the Open Meetings Law, because the minimum period for notice of the meeting, twenty-four hours (24 hrs), exclusive of Saturdays, Sundays and legal holidays, was not met.

The Subsection B of La.R.S. 1:55 states “legal holidays shall be observed by the departments of state.” That statute does reference “departments of state.” Different departments of the state, for instance Department of Motor Vehicles, Department of Wildlife and Fisheries, Department of Public Safety and Corrections, those are different departments of the State. And GAEDA does not fall within the Department of the State. So therefore, Subsection B of La.R.S. 1:55 is not applicable.

The trial court issued judgment, declaring that GAEDA conducted the

February 19, 2024 meeting in violation of the Open Meeting Law; that all the actions

taken that evening, including the approval of the Executive Director Agreement, are

void and without effect; and that the Executive Director Agreement is void and

without effect.

Ms. Varnado appeals, arguing that:

A. The District Court erred in denying Appellant’s peremptory exception of no cause of action because twenty-four (24) working hours had elapsed between giving notice of the February 19, 2024, meeting and the meeting itself.

B. The District Court legally erred in its interpretation of the Open Meetings Law and the Legal Holidays Statute in finding that Washington’s Birthday was [a] legal holiday for purposes of notice calculation under the Open Meetings Law.

DISCUSSION

Justiciable Controversy

Following briefing, Ms. Varnado informed this court that GAEDA met on

February 18, 2025 and “passed a Motion to ratify and confirm the Employment

Contract issued to Ms. Angela Varnado[.]” Ms. Varnado suggests that this action may

3 have rendered her appeal moot. Plaintiff challenges Ms. Varnado’s position on both

substantive and procedural grounds.

We thus consider the threshold matter of whether this case continues to present

a justiciable controversy or whether GAEDA’s February 18, 2025 action renders this

case moot. Cat’s Meow, Inc. v. City of New Orleans through Dep’t of Fin., 98-601

(La. 10/20/98), 720 So.2d 1186. “[A]n issue is ‘moot’ when a judgment or decree on

that issue has been ‘deprived of practical significance’ or ‘made abstract or purely

academic[.]’” Id. at 1193 (quoting Perschall v. State, 96-322, p. 18 (La. 7/1/97), 697

So.2d 240, 253).

Notably, courts of appeal render judgment “upon the record on appeal” and

thus do not consider evidence that is not in the appellate record. La.Code Civ.P. art.

2164; Marco Outdoor Advert., Inc. v. Dep’t of Transp. & Dev., 21-123 (La.App. 1

Cir. 7/13/21), 329 So.3d 288, writ denied, 21-1195 (La. 11/10/21), 326 So.3d 1247.

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