State of Louisiana v. Casen Carver - Court Opinion
Summary
The Louisiana Court of Appeal issued an opinion in the case of State of Louisiana v. Casen Carver. The court denied the State's motion to recuse the trial judge, finding that while prior rulings and exposure to information did not inherently justify recusal, recusal was granted in the interest of justice and to safeguard public confidence.
What changed
The Louisiana Court of Appeal, First Circuit, issued an opinion in State of Louisiana v. Casen Carver, docket number 2025 KW 1213. The court addressed the State's motion to recuse the trial judge. While the appellate court agreed that adverse rulings and exposure to prejudicial information did not, on their own, demonstrate bias warranting recusal, they ultimately granted recusal in the interest of justice and to maintain public confidence in the judiciary, citing precedent from the Louisiana Supreme Court.
This decision does not impose new obligations on regulated entities but clarifies judicial standards for recusal. Legal professionals and courts should note the appellate court's reasoning, particularly the emphasis on safeguarding public confidence, even in the absence of proven actual bias by the trial judge. The case involved a criminal matter, and the specific grounds for recusal related to alleged prejudicial information regarding the victim's sexual history.
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March 19, 2026 Get Citation Alerts Download PDF Add Note
State Of Louisiana v. Casen Carver
Louisiana Court of Appeal
- Citations: None known
- Docket Number: 2025 KW 1213
Precedential Status: Unknown Status
Combined Opinion
STATE OF LOUISIANA
COURT OF APPEAL, FIRST CIRCUIT
STATE OF LOUISIANA NO. 2025 KW 1213
VERSUS
CASEN CARVER MARCH 19, 2026
In Re: Casen Carver, applying for supervisory writs, 19th
Judicial District Court, Parish of East Baton Rouge, No.
DC-23-02251.
BEFORE: McCLENDON, C.J., GREENE AND STROMBERG, JJ.
WRIT DENIED. The State’s motion to recuse is timely, as it
was filed the day after discovery of the fact constituting the
ground upon which the motion is based and more than thirty days
prior to the previously scheduled trial date. We agree that the
prior rulings by the trial judge and the judge’s exposure to
allegedly prejudicial information regarding the victim’s prior
sexual history do not justify recusal, as adverse rulings performed
within a judge’s authority do not show bias or prejudice warranting
recusal. See State v. Clues~Alexander, 2024-95 (ha. App. 3d Cir.
4/16/25), 409 So.3d 532, 539, writ denied, 2025-00634 (La.
11/25/25), 421 So.3d 535. There has been no allegation or showing
that the trial judge harbors any actual bias or that she is not a
diligent district court judge. However, in the interest of justice
and to safeguard public confidence in the judiciary, the standard
enunciated by the Louisiana Supreme Court requires recusal in this
matter. See e.g., State v. Mire, 2023-01010 (La. 12/5/23), 373
So.3d 709 (per curiam).
PMc
HG
TPS
OURT OF APPEAL, FIRST CIRCUIT
wha 4). Were
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EPUTY CLERK OF COURT
FOR THE COURT
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