Summary
The Louisiana First Circuit granted supervisory writs and vacated the district court’s ruling excluding the opinions of an expert witness. The court held that the district court failed to comply with Louisiana Code of Civil Procedure article 1425(F), which requires findings of fact, conclusions of law, and reasons concerning whether a person may testify under Louisiana Code of Evidence articles 702 through 705, and remanded for compliance.
Topics
Practice areas
Questions Presented
- Whether the district court erred by granting a motion to exclude expert opinions without providing the findings of fact, conclusions of law, and reasons for judgment required by Louisiana Code of Civil Procedure article 1425(F).
Holdings
- The district court committed legal error by failing to comply with Louisiana Code of Civil Procedure article 1425(F), which requires findings of fact, conclusions of law, and reasons for judgment explaining why a person is allowed or disallowed to testify under Louisiana Code of Evidence articles 702 through 705.
Key quotations
“We find the district court committed legal error by failing to comply with La. Code Civ. P. art. 1425(F), which requires the trial court to provide findings of fact, conclusions of law, and reasons for judgment detailing in law and fact why a person shall be allowed or disallowed to testify under La. Code Evid. arts. 702 through 705.”
“We therefore vacate the district court’s May 5, 2025 ruling granting the motion to exclude the opinions of Mr. Blackman and remand the matter to the district court with instructions to comply with La. Code Civ. P. art. 1425.”
Factual background
The district court considered a motion to exclude the opinions of Mr. Blackman under the Louisiana expert-testimony provisions. The court orally granted the motion on May 5, 2025, but provided no written judgment or written reasons and did not make the findings of fact and conclusions of law required by article 1425(F).
Procedural history
The matter originated in the 21st Judicial District Court for Tangipahoa Parish, case number 2021-0000678. On May 5, 2025, the district court orally granted a motion to exclude Mr. Blackman's opinions but did not issue a written judgment or findings of fact, conclusions of law, and reasons addressing the admissibility requirements. Harris sought supervisory review, and the court of appeal granted the writ and remanded for compliance with Louisiana Code of Civil Procedure article 1425.
Remand instructions
Vacate the district court's May 5, 2025 ruling granting the motion to exclude Mr. Blackman's opinions and remand for the district court to comply with Louisiana Code of Civil Procedure article 1425.