Background
Hannah Q Smokehouse, LLC and Twin City Fire Insurance Company sought supervisory review of a ruling by the 19th Judicial District Court in East Baton Rouge Parish. The district court had denied their motion in limine to exclude the expert testimony of Eric Parnell.
The district court gave oral reasons for its ruling. The defendants contended that those reasons did not satisfy Louisiana Code of Civil Procedure article 1425(F), which governs the findings and explanations required when a court allows or disallows expert testimony under Louisiana Code of Evidence articles 702 through 705.
The Court’s Holding
The First Circuit granted the supervisory writ and held that the district court committed legal error by failing to comply with article 1425(F). That provision requires findings of fact, conclusions of law, and reasons for judgment explaining in law and fact why the proposed witness will be allowed or disallowed to testify.
The appellate court concluded that the district court’s oral reasons did not meet those requirements. It therefore vacated the April 2, 2026 judgment denying the motion in limine and remanded with instructions for the district court to comply with article 1425(F).
Key Takeaways
- A ruling admitting or excluding expert testimony must include the findings, legal conclusions, and reasons required by Louisiana Code of Civil Procedure article 1425(F).
- Oral reasons are insufficient when they do not explain in law and fact why the expert is allowed or disallowed to testify.
- The First Circuit did not decide whether Eric Parnell’s testimony was admissible; it vacated the ruling and required the district court to perform and document the prescribed analysis.
Why It Matters
The decision underscores that Louisiana trial courts must create an adequately reasoned record when resolving challenges to expert testimony. A court’s failure to provide the analysis mandated by article 1425(F) can require vacatur and remand even without an appellate determination on the expert’s ultimate admissibility.