Ocean Jasmine Manning v. State of Louisiana

CourtLouisiana Court of Appeal
DecidedSeptember 23, 2020
DocketCA-0019-0698
StatusUnknown

This text of Ocean Jasmine Manning v. State of Louisiana (Ocean Jasmine Manning v. State of Louisiana) 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
Ocean Jasmine Manning v. State of Louisiana, (La. Ct. App. 2020).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL, THIRD CIRCUIT

19-698

OCEAN JASMINE MANNING

VERSUS

************ APPEAL FROM FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. 2018-6455 HONORABLE EDWARD D. RUBIN, DISTRICT JUDGE

************ CANDYCE G. PERRET JUDGE ************

Court composed of Sylvia R. Cooks, John D. Saunders, Billy H. Ezell, Candyce G. Perret, and Jonathan W. Perry, Judges.

AFFIRMED.

Cooks, J., dissents with written reasons. Saunders, J., dissents. Richard Ducote 318 E. Boston Street, 2nd Floor Covington, LA 70433 (985) 898-2755 Attorney for Appellant/Plaintiff Ocean Jasmine Manning

Paul D. Gibson Thomas M. Long 412 Travis Street, Suite C Lafayette, LA 70503 (337) 233-9600 Attorneys for Appellee Keith A. Stutes, District Attorney, 15th Judicial District

2 PERRET, Judge.

In this case, we consider whether the trial court erred in denying a

declaratory judgment decreeing Plaintiff Ocean Jasmine Manning (“Ms.

Manning”) factually innocent of crimes for which she was arrested in 2015.

FACTS AND PROCEDURAL HISTORY:

Ms. Manning, an Oklahoma resident, has two children, a nine-year-old and a

seven-year-old, who live in Lafayette, Louisiana, with their father pursuant to an

Oklahoma custody decree. Ms. Manning was arrested on June 22 or June 23, 2015

in Lafayette Parish after being extradited from Oklahoma. Ms. Manning was

charged with three counts of abuse of children/false reports, violations of La.R.S.

14:403(A)(3); two counts of criminal mischief/false report or complaint, violations

of La.R.S. 14:59(A)(5), and three counts of cruelty to juveniles, violations of

La.R.S. 14:93(A)(1), involving her children.

No Bill of Information or Indictment was filed in connection with these

charges. The Fifteenth Judicial District, Parish of Lafayette’s District Attorney’s

Office indicated at a trial court hearing that it “has no intent to prosecute” Ms.

Manning for these charges. The District Attorney’s Office reiterated this fact in its

brief to this court.

Thereafter, Ms. Manning filed a Petition for Declaratory Judgment in civil

court, asserting that her arrest and the publicity stemming from her arrest has

prejudiced her Oklahoma child custody proceedings. Additionally, she asserts that

she “never committed any of these alleged crimes and is factually innocent.” Ms.

Manning sought a declaratory judgment of her factual innocence because she “has

no adequate remedy to clear her name and to rectify these false charges of criminal

conduct” and that such judgment is appropriate under La.Code Civ.P. arts. 1871– 1888. Ms. Manning named the State of Louisiana (“the State”) as a Defendant and

served the State through the District Attorney for the Parish of Lafayette, 15th

Judicial District, Hon. Keith Stutes (“the District Attorney”).

The District Attorney filed Declinatory Exceptions of Improper Citation and

Insufficiency of Service of Process, and Lack of Subject Matter Jurisdiction;

Dilatory Exceptions of Prematurity, and Improper Joinder of Parties; and

Peremptory Exceptions of Prescription, No Cause of Action, and No Right of

Action. First, the District Attorney argued that serving the District Attorney was

improper and insufficient service on the State, as the District Attorney’s Office is

not a state agency. Second, the District Attorney argued that the district court in its

civil capacity lacked subject matter jurisdiction over criminal matters. Third, the

District Attorney argued that this suit is premature because the District Attorney

has not taken any steps towards the prosecution of Ms. Manning and there have

been no adverse actions, no “judiciable controversy” exists for the court to decide.

Fourth, the District Attorney argued that the District Attorney’s Office was

improperly joined because it was not named as a defendant and is not an agency of

the State. Fifth, the District Attorney alleged that Ms. Manning’s claims arising

from her 2015 arrest sound in tort and are prescribed. Lastly, the District Attorney

claims there is no cause of action and no right of action as an adequate remedy

exists under the court’s criminal jurisdiction (expungement) and because there is

currently no justiciable controversy.

The trial court sustained all exceptions and dismissed Ms. Manning’s

petition. On appeal, Ms. Manning assigns eight assignments of error, which

together allege that the trial court erred in sustaining the District Attorney’s

exceptions.

2 ANALYSIS:

After reviewing the record on appeal, we agree with the trial court in

sustaining the exceptions of prematurity and no cause of action. As these findings

ultimately affirm the dismissal of Ms. Manning’s petition, a discussion of the trial

court’s error in sustaining the remaining exceptions would be superfluous.

Dilatory exception of prematurity:

“The dilatory exception of prematurity provided in La.Code Civ.Proc. art.

926 questions whether the cause of action has matured to the point where it is ripe

for judicial determination.” Williamson v. Hosp. Serv. Dist. No. 1 of Jefferson, 04-

451, p. 4 (La. 12/1/04), 888 So.2d 782, 785. “An action is premature when it is

brought before the right to enforce it has accrued.” Id. The party raising the

exception carries the burden of proving prematurity. Id. On appeal, a judgment

granting an exception of prematurity is reviewed under the “manifest error

standard of review unless it involves a question of law.” Barlow v. Garber, 17-

401, p. 2 (La.App. 3 Cir. 11/2/17), 230 So.3d 1002, 1004.

Ms. Manning seeks a declaration that she is innocent of the crimes for which

she was arrested. However, Ms. Manning has not been prosecuted for those

crimes. Therefore, Ms. Manning “is presumed innocent until proven guilty[.]”

La.Const. art. 1, § 16; see generally U.S. Const. amends. V and XIV. The United

States Supreme Court has stated, “The principle that there is a presumption of

innocence in favor of the accused is the undoubted law, axiomatic and elementary,

and its enforcement lies at the foundation of the administration of our criminal

law.” Coffin v. United States, 156 U.S. 432, 453, 15 S.Ct. 394, 403 (1895). Thus,

as Appellee notes, there is no adversity between Ms. Manning and the District

3 Attorney as no charges have been filed and Ms. Manning remains legally innocent

under the law. There is no dispute for the court to resolve.

Additionally, the possibility of prosecution being instituted is unlikely given

the time restraints in La.Code Crim.P. art. 572. Louisiana Code of Criminal

Procedure Article 572 provides the time limitations for prosecution of noncapital

offenses:

A. Except as provided in Articles 571 and 571.1, no person shall be prosecuted, tried, or punished for an offense not punishable by death or life imprisonment, unless the prosecution is instituted within the following periods of time after the offense has been committed:

....

(2) Four years, for a felony not necessarily punishable by imprisonment at hard labor.

(3) Two years, for a misdemeanor punishable by a fine, or imprisonment, or both.

If Ms. Manning wants to remove the arrest from her record, our law provides

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