Summary
The Supreme Court of Louisiana disciplined Judge John C. Reeves for accepting a $100 gratuity from a litigant after signing a judgment of possession in a succession proceeding. The court imposed a 20-day suspension without pay and ordered reimbursement of $3,121.53 in hard costs, reducing the Judiciary Commission’s recommended 30-day suspension. Chief Justice Weimer concurred in part and dissented in part, favoring a lesser sanction.
Topics
Practice areas
Questions Presented
- What discipline should be imposed for Judge Reeves's stipulated violations of the Louisiana Code of Judicial Conduct and Louisiana Constitution article V, § 25(C)?
- Whether the Commission's recommended thirty-day suspension without pay was appropriate in light of the Chaisson factors, aggravating circumstances, and mitigating circumstances.
Holdings
- A suspension without pay was warranted because Judge Reeves's acceptance of the $100 gratuity from a litigant while acting in his official capacity seriously tainted the integrity and reputation of the judiciary, even though the incident was isolated, there was no proven quid pro quo, and the misconduct was not found to be in bad faith.
- The Commission's recommended thirty-day suspension was rejected, and Judge Reeves was suspended without pay for twenty days.
Key quotations
“As an elected official and public servant, a judge should not accept a monetary gratuity for performing those duties with which he has been entrusted.” (at 5)
“For the foregoing reasons, it is ordered that Judge Reeves shall be suspended from office without salary for twenty days.” (at 7)
Factual background
Judge John C. Reeves, a judge of Louisiana's Seventh Judicial District Court, signed a judgment of possession in a succession matter before the matter had been filed or allotted to him. After signing the judgment, which awarded the litigant the majority of the estate, Reeves accepted a folded $100 bill from the litigant, who said it was for lunch. The parties stipulated that Reeves violated the charged judicial-conduct canons and Louisiana Constitution article V, § 25(C); the Commission found the incident isolated and not undertaken in bad faith but seriously harmful to the judiciary's integrity.
Procedural history
An anonymous complaint led to an investigation and a Commission Notice of Hearing alleging violations of the Louisiana Code of Judicial Conduct and the Louisiana Constitution. Judge Reeves and the Office of Special Counsel stipulated to the material facts and violations, and the Commission accepted the stipulations without a hearing officer. The Commission recommended a thirty-day suspension without pay and $3,121.53 in hard costs, but the parties later waived briefing and oral argument in the Supreme Court.