State of Louisiana v. Messiah Owney

Summary

The court held that local-rule provisions authorizing an Orleans Parish Juvenile Court hearing officer to issue arrest and search warrants were invalid because they conflicted with governing statutes and the Louisiana Constitution. Nevertheless, warrants previously issued under those provisions, and the resulting arrest and seizure, remained valid under the de facto officer doctrine because the hearing officer acted under an apparently valid rule before its invalidity was judicially determined. The denial of suppression was affirmed, and the case was remanded for further proceedings.