Background
Larry English sought supervisory review in litigation brought by Sharon Lewis against Louisiana State University, its Board of Supervisors, and numerous individual and institutional defendants. His application challenged an August 13, 2026 district-court order granting contempt motions and imposing punishment and sanctions.
English also sought relief concerning other rulings, including a motion to recuse and a rule to show cause signed on July 21, 2026. He requested review of those separate rulings in the same writ application and sought a stay.
The Court’s Holding
The First Circuit held that the August 13 contempt-and-sanctions order was an appealable judgment under Louisiana law. Because English had an adequate appellate remedy, the court granted the writ only to remand the matter with instructions that the district court grant him an appeal pursuant to his notice of intent to seek supervisory writs. It also ordered that a copy of its ruling be included in the appellate record.
The court denied a stay and declined to consider the remaining requested relief because English improperly sought supervisory review of multiple rulings in one writ application. It directed him to file a separate application for each ruling, with all pertinent documentation and a copy of the court’s ruling, by September 3, 2026. The court also stated that it would not consider supplementation of the existing application or an application for rehearing.
Key Takeaways
- An order imposing contempt punishment and sanctions is an appealable judgment, making appeal the proper route for review.
- When a party mistakenly seeks supervisory review of an appealable contempt judgment, the appellate court may remand with instructions to grant an appeal.
- A litigant seeking supervisory review of multiple distinct rulings must file a separate writ application for each ruling.
Why It Matters
The ruling underscores the importance of selecting the correct procedural vehicle to challenge contempt sanctions in Louisiana courts. A party aggrieved by an appealable contempt judgment should pursue an appeal rather than rely solely on supervisory review.
It also highlights the First Circuit’s application-specific filing rule: combining multiple rulings in one supervisory writ application can prevent the court from considering otherwise reviewable issues.