Narrative Opinion Summary
In this appellate case, the Vermilion Parish Police Jury (VPPJ) contests a trial court's order requiring them to finance pre-adjudicative housing expenses for juveniles arrested by city police in Abbeville and Kaplan, and detained at facilities outside Vermilion Parish. Historically, these costs were covered by the VPPJ until June 2010, when they ceased payments citing Louisiana Children's Code Article 815. The cities of Abbeville and Kaplan sought a writ of mandamus, contesting the VPPJ's interpretation of Article 815 and asserting that the custom of payment established a legal obligation. The trial court found Article 815 inapplicable, as the Lafayette Juvenile Detention Home and St. Martin Parish Detention Center are not deemed 'regional detention centers.' The appellate court reversed this decision, emphasizing that these facilities do not fall under the specified categories in Article 815, and that customary practices could not supersede legislative authority without sufficient evidence. The case was remanded for further proceedings, with appeal costs divided between the involved cities, while two judges dissented, providing separate opinions.
Legal Issues Addressed
Definition and Classification of Juvenile Detention Facilitiessubscribe to see similar legal issues
Application: The court determined that the Lafayette and St. Martin facilities do not qualify as 'regional detention centers,' affecting the application of Article 815.
Reasoning: The inquiry reveals that La. Ch. Code art. 815(E) specifically pertains to regional detention and shelter care facilities, which the Lafayette and St. Martin facilities are not.
Interpretation of La. Ch. Code Article 815subscribe to see similar legal issues
Application: The VPPJ argued that Article 815 does not obligate them to pay for detentions initiated by city police in non-regional facilities, a position the appellate court supported.
Reasoning: The discussion of Article 815 clarifies the responsibilities and authorities regarding the detention of juveniles, including guidelines for transporting and placing detained youths.
Obligation to Pay Juvenile Detention Costssubscribe to see similar legal issues
Application: The trial court found that the Vermilion Parish Police Jury (VPPJ) must cover housing costs for juveniles detained out-of-parish, ruling Article 815 inapplicable as these are not 'regional detention centers.'
Reasoning: The trial court ruled that Article 815 was inapplicable, as the out-of-parish facilities do not constitute 'regional detention centers or shelter care facilities,' and mandated that the VPPJ pay the expenses.
Role of Custom in Establishing Legal Obligationssubscribe to see similar legal issues
Application: While the cities argued that VPPJ's historical payment established an obligation, the court held that custom cannot override legislative provisions without adequate evidence.
Reasoning: However, civil law states that while custom may influence legal obligations, it cannot override existing legislation.