Joseph G. Richard v. State of Louisiana Deptartment of Public Safety & Correction and Office of Motor Vehicles

CourtLouisiana Court of Appeal
DecidedJune 3, 2026
DocketCA-0025-0689
StatusUnknown

This text of Joseph G. Richard v. State of Louisiana Deptartment of Public Safety & Correction and Office of Motor Vehicles (Joseph G. Richard v. State of Louisiana Deptartment of Public Safety & Correction and Office of Motor Vehicles) 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
Joseph G. Richard v. State of Louisiana Deptartment of Public Safety & Correction and Office of Motor Vehicles, (La. Ct. App. 2026).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

25-689

JOSEPH G. RICHARD

VERSUS

STATE OF LOUISIANA, DEPARTMENT OF PUBLIC SAFETY & CORRECTIONS, OFFICE OF MOTOR VEHICLES

**********

APPEAL FROM THE FOURTEENTH JUDICIAL DISTRICT COURT PARISH OF CALCASIEU, NO. 2025-2114 HONORABLE KENDRICK J. GUIDRY, DISTRICT JUDGE

SHANNON J. GREMILLION JUDGE

Court composed of Elizabeth A. Pickett, Shannon J. Gremillion, and Sharon Darville Wilson, Judges.

Pickett, C.J., dissents and assigns written reasons.

AFFIRMED. Harrietta J. Bridges Attorney at Law 7979 Independence Boulevard, Suite 307 Baton Rouge, LA 70806 (225) 922-2311 COUNSEL FOR DEFENDANT/APPELLANT: State of Louisiana, Department of Public Safety & Corrections, Office of Motor Vehicles

Fred C. LeBleu, III Andrew T. Leonards Adam P. Johnson The Johnson Firm P.O. Box 849 Lake Charles, LA 70602 (337) 433-1414 COUNSEL FOR PLAINTIFF/APPELLEE: Joseph G. Richard 1 GREMILLION, Judge.

The defendant-appellant, the Louisiana Department of Public Safety and

Corrections (DPSC), Office of Motor Vehicles (OMV), appeals the judgment of the

trial court overturning the administrative hearing officer’s suspension of the

plaintiff’s Class E driver’s license for failure to consent to a chemical test after an

arrest for operating a vehicle while intoxicated. For the reasons that follow, we

affirm.

FACTS

While on patrol just before midnight on November 2, 2024, Louisiana State

Trooper Austen Wright clocked a northbound vehicle on Highway 171 in Calcasieu

Parish traveling twenty-two miles per hour over the posted speed limit. Trooper

Wright pursued the vehicle. While in pursuit, he observed the vehicle commit

several other traffic offenses, including twice failing to activate a turn signal before

turning, failing to stop at a stop sign, and speeding at a rate of fifty-one miles an hour

on a road with a posted speed limit of twenty-five miles per hour. When Trooper

Wright activated his emergency lights to have the vehicle pull over, the driver,

Joseph Richard continued driving several blocks until he pulled into his driveway

and stopped his vehicle.

Once stopped, Trooper Wright noticed behavior that made him suspect

Richard was intoxicated: he swayed from side to side while walking, he used his

vehicle to steady himself, and his speech was slurred. Trooper Wright also noticed

Richard’s eyes were red and glassy, and he noticed a strong smell of alcohol on his

breath. Because Richard had a disability from a work injury, Trooper Wright was

only able to administer a horizontal gaze nystagmus (HGN) test. After conducting this test, Trooper Wright determined that Richard was impaired and arrested Richard

for operating a vehicle while intoxicated.

Trooper Wright asked Richard to submit to a chemical test (Intoxilyzer 9000),

but Richard refused the test. Trooper Wright seized Richard’s license for failure to

submit to a chemical test pursuant to La.R.S. 32:667. To preserve the ability to

contest the suspension of his license, Richard requested administrative review of the

suspension within thirty days of his arrest as required by La.R.S. 32:668.

The administrative hearing was held on March 26, 2025. At that hearing,

Richard introduced a letter from the Calcasieu Parish District Attorney’s Office

indicating that the district attorney had refused to charge Richard for a violation of

La.R.S. 14:98. Richard argued that because the charge for DWI related to his arrest

would not be prosecuted, the DPSC did not have the authority under La.R.S.

32:667(H)(1)(a) to suspend Richard’s license, citing In re Lafleur, 12-1227 (La.App.

3 Cir. 3/6/13), 129 So.3d 540.

Pursuant to La.R.S. 32:668(A), the scope of this administrative hearing was

limited to the following issues:

(1) Whether a law enforcement officer had reasonable grounds to believe that the person, regardless of age, had been driving or was in actual physical control of a motor vehicle upon the public highways of this state, or had been driving or was in actual physical control of a motor-powered watercraft upon the public navigable waterways of this state, while under the influence of either alcoholic beverages or any drug, combination of drugs, or combination of alcohol and drugs.

(2) Whether the person was placed under arrest.

(3) Whether he was advised by the officer as provided in R.S. 32:661.

(4) Whether he voluntarily submitted to an approved chemical test and whether the test resulted in a blood alcohol reading of 0.08 percent or above by weight, or of 0.02 percent or above if he was under the age of twenty-one years on the date of the test.

(5) Whether he refused to submit to the test upon the request of the officer. 2 (6) Such additional matters as may relate to the legal rights of the person, including compliance with regulations promulgated by the Department of Public Safety and Corrections and rights afforded to the person by law or jurisprudence.

The hearing officer found that Trooper Wright had reasonable grounds to believe

Richard was operating his vehicle on a public highway while intoxicated. Richard

was placed under arrest. The hearing officer further found that Richard was advised

of his rights and the consequences of his failure to submit to a chemical test when

Trooper Wright read the same from the approved form provided by DPSC. Richard

did not submit to a chemical test; thus, the fourth question was deemed inapplicable

and the fifth question deemed proven.

As to the sixth factor, the hearing officer acknowledged the evidence

submitted by Richard that the district attorney had refused to charge Richard with

DWI. In his reasons for ruling, the hearing officer stated:

Counsel for Respondent’s reliance on the reinstatement provisions of La.R.S. 32:667(H)(1)(a) is misplaced. This tribunal has no jurisdiction over the reinstatement of driving privileges as required by that statute. This tribunal’s sole inquiry is whether the suspension of driving privileges by DPS was proper at the time those driving privileges were suspended. The issue of reinstatement of those driving privileges falls under the umbrella of issues that a district court has jurisdiction over. The issue of suspension of driving privileges, which is tasked to this tribunal, is distinct from the issue of the reinstatement of those driving privileges. It is why the Lafleur court made special mention of that distinction in its decision and did not comment on the validity of the administrative law judge’s decision to affirm the suspension by DPS.

It follows that the underlying suspension’s validity, and consequently the relevance of the instant hearing, is not affected by the dismissal or other disposition of criminal charges. The suspension, when upheld by the administrative tribunal, may be used to enhance any future suspensions of Respondent’s driving privileges if he is arrested for future DWIs, even though Respondent may be eligible to have his driving privileges reinstated.

Richard filed an Application for Judicial Review of the hearing officer’s

ruling pursuant to La.R.S. 32:668(C). The district court issued an order staying the

3 enforcement of the suspension pending judicial review. The district court conducts

a de novo review of the findings of the hearing officer. Clark v. Louisiana Dep’t of

Pub. Safety, 13-1431 (La.App. 3 Cir. 5/17/14), 139 So.3d 635. At the hearing in the

district court, OMV called Trooper Wright to the stand to testify to the circumstances

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Related

Nunnally v. STATE, DEPT. OF PUBLIC SAFETY & CORR.
663 So. 2d 254 (Louisiana Court of Appeal, 1995)
Murphy v. State Through DPS
640 So. 2d 546 (Louisiana Court of Appeal, 1994)
Brooks v. Louisiana Dept. of Public Safety & Corrections
66 So. 3d 1236 (Louisiana Court of Appeal, 2011)
Brown v. City of Shreveport
129 So. 2d 540 (Louisiana Court of Appeal, 1961)
In re Lafleur
129 So. 3d 540 (Louisiana Court of Appeal, 2013)
Clark v. Louisiana Department of Public Safety
139 So. 3d 635 (Louisiana Court of Appeal, 2014)
Brooks v. Louisiana Dept. of Public Safety & Corrections
75 So. 3d 948 (Supreme Court of Louisiana, 2011)
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Joseph G. Richard v. State of Louisiana Deptartment of Public Safety & Correction and Office of Motor Vehicles, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-g-richard-v-state-of-louisiana-deptartment-of-public-safety-lactapp-2026.