State v. Damien Chance White - Subpoena Reversed, Discovery Order Quashed
Summary
Louisiana Court of Appeal, First Circuit reversed a district court discovery order requiring the State to produce all communications between the District Attorney's Office and witnesses. The appellate court held that witness statements are normally not discoverable under La. Code Crim. P. art. 723(A), and the defendant failed to show the requests were relevant, specific, and made in good faith rather than as a general fishing expedition.
What changed
The Louisiana Court of Appeal reversed a district court order compelling the State to produce all communications between the District Attorney's Office and prosecution witnesses. The appellate court found the defendant's discovery request did not specifically identify statements containing impeachment or exculpatory evidence, and there was no showing the requested information was in the DA's possession prior to trial.
Legal professionals and courts should note that broad, non-specific discovery requests in criminal proceedings will not survive scrutiny. Under Louisiana law, witness statements are ordinarily not discoverable, and defendants must make particularized showings of relevance, specificity, and good faith before obtaining such materials.
What to do next
- Monitor for further proceedings
Archived snapshot
Apr 14, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Jump To
Top Caption Combined Opinion The text of this document was obtained by analyzing a scanned document and may have typos.
Support FLP
CourtListener is a project of Free
Law Project, a federally-recognized 501(c)(3) non-profit. Members help support our work and get special access to features.
Please become a member today.
April 13, 2026 Get Citation Alerts Download PDF Add Note
State Of Louisiana v. Damien Chance White
Louisiana Court of Appeal
- Citations: None known
- Docket Number: 2025 KW 1250
Precedential Status: Unknown Status
Combined Opinion
STATE OF LOUISIANA
COURT OF APPEAL, FIRST CIRCUIT
STATE OF LOUISIANA NO. 2025 KW 1250
VERSUS
DAMIEN CHANCE WHITE APRIL 13, 2026
In Re: State of Louisiana, applying for supervisory writs, 22nd
Judicial District Court, Parish of St. Tammany, No.
1444-F-2022.
BEFORE : THERIOT, PENZATOC, AND BALFOUR, JJ.
STAY LIFTED. WRIT GRANTED. Witness statements are normally
not discoverable. See La. Code Crim. P. art. 723(A). Furthermore,
the moving party must show that the documents are evidentiary and
relevant and that the application is made in good faith and is not
intended as a general fishing expedition. State v. Marcelin, 2010-
2036 (La. 10/15/10), 46 So.3d 191, 193 (per curiam); State v.
Johnson, 2000-0680 (La. App. Ist Cir. 12/22/00), 775 So.2d 670,
676, writ denied, 2002-1368 (La. 5/30/03), 845 So.2d
1066. Additionally, the victim shall be protected at all times by
all rules and laws governing the criminal procedure and the
admissibility of evidence applicable to criminal proceedings. La.
R.S. 46:1844(I). The defendant’s request does not specifically
identify a statement in the St. Tammany Parish District Attorney’s
file that contains impeachment and/or exculpatory
evidence. Furthermore, there was no showing that the information
that defendant describes as suppressed was ever in the possession
of the district attorney’s office prior to the trial of this
matter. Thus, the defendant failed to show that his broad request
for any and all communications between the District Attorney’s
Office and the prosecution’s witnesses is relevant, admissible,
and specific. Therefore, the district court abused its discretion
by ordering the State to provide the defense with such
information. Accordingly, the district court’s ruling ordering
the State to provide the defendant with any and all communications
between the District Attorney’s Office and all the witnesses named
in each category (one through six) is reversed and the subpoena
duces tecum is quashed. The stay previously issued by this court
in this matter is lifted and this matter is remanded for further
proceedings.
AHP
MRT
Balfour, J., dissents and would deny the writ application.
“NCOURT OF APPEAL, FIRST CIRCUIT
“yy (|
RK OF COURT
FOR THE COURT
Named provisions
Related changes
Get daily alerts for Louisiana Court of Appeal
Daily digest delivered to your inbox.
Free. Unsubscribe anytime.
About this page
Every important government, regulator, and court update from around the world. One place. Real-time. Free. Our mission
Source document text, dates, docket IDs, and authority are extracted directly from LA Ct. App. 1st Cir..
The summary, classification, recommended actions, deadlines, and penalty information are AI-generated from the original text and may contain errors. Always verify against the source document.
Classification
Who this affects
Taxonomy
Browse Categories
Get alerts for this source
We'll email you when Louisiana Court of Appeal publishes new changes.
Subscribed!
Optional. Filters your digest to exactly the updates that matter to you.