State of Louisiana v. Maureen Vallot

CourtLouisiana Court of Appeal
DecidedApril 5, 2006
DocketCA-0005-0532
StatusUnknown

This text of State of Louisiana v. Maureen Vallot (State of Louisiana v. Maureen Vallot) 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
State of Louisiana v. Maureen Vallot, (La. Ct. App. 2006).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

05-0532

STATE OF LOUISIANA

VERSUS

MAUREEN VALLOT

************

APPEAL FROM THE SIXTEENTH JUDICIAL DISTRICT COURT, PARISH OF IBERIA, NO. 03-J-935, HONORABLE KEITH COMEAUX, DISTRICT JUDGE

JIMMIE C. PETERS JUDGE

Court composed of Jimmie C. Peters, Michael G. Sullivan and Glenn B. Gremillion, Judges.

REVERSED AND REMANDED.

A. C. Elias District Attorney’s Office Non-Support Division 300 Iberia Street New Iberia, LA 70560 (337) 369-4434 COUNSEL FOR APPELLEE: State of Louisiana

Maureen Vallot 7739-A Main Highway St. Martinville, LA 70582 (337) 364-7945 In Proper Person PETERS, J.

Maureen Vallot appeals a trial court judgment ordering her to pay to the

Louisiana Department of Social Services, Support Enforcement Division, the sum of

$200.00 per month as child support for two of her minor children together with an

additional five percent per month administration fee. For the following reasons, we

reverse the trial court judgment and remand the matter for further proceedings.

APPLICABLE LAW

Understanding the current status of this litigation is next to impossible without

first considering the applicable statutes and the procedure mandated by those statutes.

In considering the applicable statutes, we note that this litigation began on November

14, 2003, when the State of Louisiana (state) filed a bill of information charging Mrs.

Vallot with criminal neglect of family, a violation of La.R.S. 14:74.

Louisiana Revised Statutes 14:74(A)(1)(b), which is the applicable section of

the statute, provides that “[c]riminal neglect of family is the desertion or intentional

nonsupport . . . [b]y either parent of his minor child who is in necessitous

circumstances, there being a duty established by this Section for either parent to

support his child.” The penalty for violation of this statute is provided for in La.R.S.

14:74(D)(1), which provides that “[w]hoever commits the offense of criminal neglect

of family shall be fined not more than five hundred dollars or be imprisoned for not

more than six months, or both, and may be placed on probation pursuant to R.S.

15:305.” Additionally, the trial court “may issue a support order, after considering

the circumstances and financial ability of the defendant, directing the defendant to

pay a certain sum at such periods as the court may direct.” La.R.S. 14:74(D)(2).

Obviously, the trial court’s power to impose the punishment provided for in La.R.S.

14:74(D) is conditioned upon a defendant being first convicted of the offense. The reference to La.R.S. 15:305 in La.R.S. 14:74(D)(1) is a reference to a

special probation statute, the application of which is limited to neglect of family

cases. It provides in pertinent part:

Whenever a person has pleaded guilty or been found guilty of the misdemeanor of criminal neglect of family or has been found in contempt of court for failing to pay support as ordered under the provisions of Children’s Code Article 1353, the judge may suspend the execution or imposition of sentence and release the offender on unsupervised probation or probation under the supervision of the Department of Social Services. The judge may suspend the sentence and place the defendant on probation although he has begun to serve the sentence imposed and may impose any specific conditions reasonably related to the offender’s rehabilitation, including but not limited to the conditions of probation as set forth in Code of Criminal Procedure Article 895.

La.R.S. 15:305(A)(1).

As suggested by the reference to La.Ch.Code art. 1353 in the above statute, the

offense of criminal neglect of family is also addressed in the Louisiana Children’s

Code in Articles 1351 through 1355. Specifically, La.Ch.Code art. 1352 provides:

A. With the consent of the defendant, at any time prior to a trial on a charge of criminal neglect of family brought pursuant to R.S. 14:74 the court, in lieu of imposing the punishment herein before provided, may issue a support order, after considering the circumstances and financial ability of the defendant, directing the defendant to pay a certain sum, at such periods as the court directs, and to maintain health care insurance.

B. This support shall be ordered payable to the applicable payee.

C. The amount of support as set by the court may be increased or decreased as the circumstances may require.

D. The court may also require the defendant to enter into a recognizance, with or without surety, in order to insure the payment of support and the maintenance of health care insurance. The condition of the recognizance shall be that the defendant shall make his or her personal appearance in court whenever required to do so, and shall further comply with the terms of the order or of any subsequent modification thereof.

2 The “applicable payee” referred to in La.Ch.Code art. 1352(B) is defined as “the

spouse, the tutor or custodian of the child, the court-approved fiduciary of the spouse

or child, or the [Louisiana Department of Social Services] in a FITAP case or in a

non-FITAP case in which the department is rendering services as designated by the

court to be the payee.” La.Ch.Code art. 1351(6). The abbreviation “FITAP” refers

to the Family Independence Temporary Assistance Program. La.Ch.Code art.

1351(5). Additionally, La.Ch.Code art. 1353, which is referred to in La.R.S.

15:305(A)(1), purports to provide for punishment for a defendant who has violated

an order issued pursuant to La.Ch.Code art. 1352.

Despite the specific language of La.Ch.Code art. 1352, a criminal neglect

proceeding is not always a prerequisite to a stipulation with regard to support under

the Children’s Code. Specifically, La.Ch.Code art. 1355 provides:

In cases in which the responsible parent or other person owing a duty of support and the district attorney stipulate to an order of support, the court shall have the power to issue an order of support under the provisions of Article 1352 without the necessity of instituting criminal proceedings pursuant to R.S. 14:74.

With this understanding of the applicable procedure, we turn to a discussion

of the history of this litigation.

PROCEDURAL AND FACTUAL HISTORY

The state charged Mrs. Vallot with criminal neglect of family by a bill of

information filed November 14, 2003. The bill of information is short on detail and

simply states that Mrs. Vallot “[d]id intentionally fail and neglect to support [her] 2

(TWO) minor children, they being persons of necessitous circumstances in violation

of the provisions of R.S. 14:74 of the State of La.”

3 Despite charging Mrs. Vallot with the offense, the state has not pursued this as

a criminal charge. Instead, on January 16, 2004, a preprinted form was filed in the

record, reflecting that the hearing officer of the Sixteenth Judicial District Court had

held a hearing on that day addressing Mrs. Vallot’s obligation to provide her minor

children with medical support. The hearing officer checked boxes on the preprinted

form recommending that the trial court issue an immediate income assignment order

and an immediate medical support order directed to Mrs. Vallot. In a blank on the

form used to describe the nature of the proceedings, the hearing officer placed the

notation “M/S only.” We interpret this notation to indicate that the hearing was for

the purpose of considering the medical support issue. Although the form states that

only Mrs.

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