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State ex rel. O'Banion v. State

Citations: 959 So. 2d 484; 2007 La. LEXIS 1596; 2007 WL 2107780Docket: No. 2006-KH-2440

Court: Supreme Court of Louisiana; June 22, 2007; Louisiana; State Supreme Court

Narrative Opinion Summary

Writs were applied for by James H. O’Banion Jr. in the case against the St. Bernard Parish Clerk of Court, seeking access to public records. The Court of Appeal, Fourth Circuit, granted the writ in part, directing the Clerk of Court to provide O’Banion with an estimate of the reproduction costs for the requested public records, which he is entitled to under Louisiana law. References include Louisiana Constitution Article XII, Section 3, and several statutes (R.S. 44:31; R.S. 44:31.1), as well as case law from State ex rel. Leonard v. State, State ex rel. Level v. State, and Range v. Moreau. If the requested documents have been destroyed, the Clerk must notify both O’Banion and the Court. The application was denied in all other respects.

Legal Issues Addressed

Obligation to Notify When Public Records Are Destroyed

Application: The court required the Clerk of Court to notify both the applicant and the court if the requested public records have been destroyed.

Reasoning: If the requested documents have been destroyed, the Clerk must notify both O’Banion and the Court.

Right to Access Public Records under Louisiana Constitution

Application: The court affirmed the applicant's right to access public records as per the Louisiana Constitution, mandating that the Clerk of Court provide necessary information regarding reproduction costs.

Reasoning: The Court of Appeal, Fourth Circuit, granted the writ in part, directing the Clerk of Court to provide O’Banion with an estimate of the reproduction costs for the requested public records, which he is entitled to under Louisiana law.

Statutory References for Access to Public Records

Application: The court's decision was guided by specific statutory references, reinforcing the legal framework governing public records access.

Reasoning: References include Louisiana Constitution Article XII, Section 3, and several statutes (R.S. 44:31; R.S. 44:31.1), as well as case law from State ex rel. Leonard v. State, State ex rel. Level v. State, and Range v. Moreau.