State of Louisiana v. Wanda Ledet

• Court: Louisiana Court of Appeal
• Decided: March 9, 2026
• Docket: 2026-K-0115
• Status: Published
• Author: Judge Tiffany Gautier Chase

Opinion

STATE OF LOUISIANA * NO. 2026-K-0115

VERSUS * COURT OF APPEAL WANDA LEDET * FOURTH CIRCUIT * STATE OF LOUISIANA *******

APPLICATION FOR WRITS DIRECTED TO CRIMINAL DISTRICT COURT ORLEANS PARISH NO. 550-585, SECTION “J” Honorable Franz Zibilich, Judge, ad hoc ****** Judge Tiffany Gautier Chase ****** (Court composed of Judge Tiffany Gautier Chase, Judge Dale N. Atkins, Judge Karen K. Herman)

Jason Rogers Williams District Attorney Brad Scott Chief of Appeals Zachary M. Phillips Assistant District Attorney Orleans Parish District Attorney’s Office 619 South White Street New Orleans, LA 70119

COUNSEL FOR RELATOR STATE OF LOUISIANA

James Miller Orleans Public Defenders Office 2601 Tulane Avenue, Suite 700 New Orleans, LA 70119

COUNSEL FOR RESPONDENT WANDA LEDET

WRIT GRANTED; JUDGMENT REVERSED MARCH 9, 2026 TGC DNA KKH

Relator, State of Louisiana (hereinafter “the State”), seeks review of the

district court’s January 8, 2026 ruling granting Respondent, Wanda Ledet’s,

motion to suppress statements. After consideration of the writ application and the

applicable law, we grant the writ and reverse the district court’s January 8, 2026

ruling granting the motion to suppress statements.

Relevant Facts and Procedural History

In August 2020, officers with the New Orleans Police Department responded

to a call at 2005 Clouet Street based upon a report that “someone [was] on the

ground with blood.” Officer Jacquen Hunter was one of the officers present at the

scene. Officer Hunter’s body worn camera footage shows Respondent behind a

locked gate holding a bloody knife in her hand. The officers attempted to gain

entry into the house by talking to Respondent. However, after the officers’

attempts failed, the fire department breached the front door and Respondent

retreated to a bedroom. The fire department breached the bedroom door and the

officers subdued Respondent, relocating her to the back of a police vehicle. The

body worn camera footage shows an elderly woman, later identified as

1 Respondent’s mother, lying unresponsive on the floor in the bedroom where

Respondent was located. Respondent was later read Miranda warnings at the

hospital after being transported for evaluation.1 Prior to being administered

Miranda warnings at the hospital, Respondent admitted to stabbing her mother.

On October 22, 2020, a grand jury indicted Respondent on one count of

first-degree murder, in violation of La. R.S. 14:30, and one count of resisting an

officer, in violation of La. R.S. 14:108. Respondent filed omnibus motions,

including a motion to suppress statements. Respondent argued that any statements

made at the scene, and prior to issuance of the Miranda warnings, should be

suppressed. The State opposed the motion contending that Respondent was

detained at the house but not yet in custody. The State further maintained that

Respondent’s statements were not given in response to a custodial interrogation.

As such, according to the State, Miranda was not triggered. The district court

requested a transcript of Respondent’s statements and ordered each side to identify

whether each statement should be admissible, or not, and explain “why.” The

district court considered the matter and issued a preliminary ruling finding

Respondent was in custody, for Miranda purposes, from her initial engagement

with the police and suppressed certain statements made by Respondent. On

January 8, 2026, the State appeared before the district court to notice its intent to

seek supervisory review of the ruling on Respondent’s motion to suppress. The

district court clarified that it had not actually ruled on the motion and stated that it

1 Miranda v. Arizona, 384 U.S. 436, 444, 86 S.Ct. 1602, 1612, 16 L.Ed.2d 694 (1966) provides

the following:

[T]he prosecution may not use statements, whether exculpatory or inculpatory, stemming from custodial interrogation of the defendant unless it demonstrates the use of procedural safeguards effective to secure the privilege against self- incrimination.

2 was “ready to make a partial amendment to [its] ruling.” The district court

specified “in” or “out” for each statement made by Respondent and determined

each statement’s admissibility. This application for supervisory review followed.2

Discussion

The State’s writ application seeks review of the district court’s January 8,

2026 ruling partially granting Respondent’s motion to suppress statements. The

State asserts the district court abused its discretion in suppressing certain

statements made by Respondent during her initial encounter with the police.3 This

court reviews a district court’s ruling on a motion to suppress under an abuse of

discretion standard of review for factual determinations and de novo for legal

determinations. State v. Candebat, 2013-0780, pp. 6-7 (La.App. 4 Cir. 1/30/14),

133 So.3d 304, 308 (citation omitted).

The dispositive issue in this matter is whether the police officers’

questioning of Respondent, upon their arrival to the scene, triggered Miranda

protections. “Miranda only applies if three conditions are met: (1) the defendant is

in ‘custody’ or significantly deprived of freedom, (2) there is an ‘interrogation,’

and (3) the interrogation is conducted by a ‘law enforcement officer’ or someone

acting as their agent.” State v. Bernard, 2009-1178, p. 5 (La. 3/16/10), 31 So.3d

1025, 1029. Custody is determined based on the circumstances surrounding the

interrogation and an evaluation of how a reasonable person in the defendant’s

position would gauge his freedom. State v. Hankton, 2012-0466, p. 13 (La.App. 4

2 On March 2, 2026, this Court requested that Respondent file an opposition to the State’s writ

application. 3 The State also assigns as error the district court “suppressing all remaining statements, including post-Miranda statements, which Defendant did not properly present to the court for its consideration.” However, a review of the transcript does not reveal that the trial court suppressed post-Miranda statements. Nonetheless, our review considers the ruling on the motion to suppress as a whole.

3 Cir. 4/30/14), 140 So.3d 398, 407. Thus, we must first determine whether an

interrogation occurred.

The United States Supreme Court recognized that a brief detention and

preliminary questioning of a suspect, to determine whether a crime has been

committed, is not a custodial interrogation requiring the protections of Miranda.

Berkemer v. McCarty, 468 U.S. 420, 439-40, 104 S.Ct. 3138, 3150, 82 L.Ed.2d

317 (1984). Further, this Court has determined that initial questioning of a

defendant is not part of a custodial detention based on the totality of the

circumstances. State v. Hill, 2025-0316, pp. 16-17 (La.App. 4 Cir. 8/19/25), 418

So.3d 1119, 1130-31. As such, a suspect’s responses to public, “on-the-scene and

non-custodial questioning,” are admissible without Miranda warnings. State v.

Shirley, 2008-2106, p. 8 (La. 5/5/09), 10 So.3d 224, 229-30. In the case sub judice,

Respondent held a bloody knife in her hand during the entire encounter with police

officers. Meanwhile, the victim was bleeding and unresponsive, but still breathing,

in the house where Respondent denied the police officers entry. We acknowledge

that the police officers questioned Respondent; however, their stated objective was

to assess and de-escalate the situation. The questions were intended to engage

Respondent and gain access to the house. We do not find the questions were

strategically designed to develop insight into criminal activity. Based on the

totality of the circumstances, we find the police officers did not actively conduct a

custodial interrogation and therefore, it was not necessary to provide Miranda

warnings at the scene. Further, the district court’s approach of categorizing each

statement as “in” or “out” would have an impractical effect during trial when

attempting to present the admissible statements while shielding the jury from the

4 statements deemed inadmissible. Accordingly, we grant the writ and reverse the

district court’s January 8, 2026 ruling granting the motion to suppress statements.

WRIT GRANTED; JUDGMENT REVERSED