State of Louisiana v. Vonnie Frank Todd, Jr.

Summary

The Louisiana First Circuit partially granted and partially denied supervisory writs in a post-conviction relief matter. The court held that the 2025 amendments to the post-conviction relief articles could not be applied retroactively to the relator’s 2013 filings, vacated the district court’s rulings on those filings, and remanded for further proceedings under the law in effect when they were filed; it upheld the denial of relief as to the untimely 2024 supplemental memorandum.

Holdings

1. The 2025 amendments could not be applied retroactively because they contained no express statement of retroactive application. Applying La. Code Crim. P. art. 927.1 to dismiss Todd's 2013 application and first supplement was impermissible.
2. Because Todd's counseled 2024 supplemental memorandum was filed after the statutory deadline, and no exception under La. Code Crim. P. art. 930.8 applied, the district court lacked authority to extend the legislatively prescribed time limits.

Questions Presented

1. Whether the 2025 amendments to Louisiana's postconviction-relief articles could be applied retroactively to Todd's 2013 application and first supplement.
2. Whether the district court had authority to extend the postconviction-relief filing deadlines for Todd's untimely 2024 supplemental memorandum.

Disposition

writ_granted