Case Note by Audrey E. Martin
Following the Fifth Circuit's decision in Caliste v. Cantrell, 937 F.3d 525 (5th Cir. 2019), Louisiana courts are at a crossroads in how they handle levying fines and judicial administration. This Note agrees with the Fifth Circuit’s holding that Judge Harry Cantrell had a conflict of interest violating due process and then explores how that unconstitutional structure is the law not just in Orleans Parish but throughout the state, concluding by looking to other state bail structures as examples of how to reform the current scheme to comply with the Constitution.
About the Author
Audrey E. Martin. J.D. candidate 2021, Tulane University Law School; B.A. 2018, Louisiana State University.
Citation
94 Tul. L. Rev. 833 (2020)