State v. Edward Schertler, II - Louisiana Court Opinion

Louisiana Court of Appeal

Filed March 9th, 2026

Detected March 9th, 2026

Summary

The Louisiana Court of Appeal reversed a district court's ruling that granted a motion to suppress evidence. The appellate court found that probable cause existed for the issuance of a search warrant, reversing the suppression and remanding the case for further proceedings.

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What changed

The Louisiana Court of Appeal, First Circuit, granted a writ of certiorari in State of Louisiana v. Edward D. Schertler, II (Docket No. 2025 KW 1286), reversing the district court's decision to grant the defendant's motion to suppress evidence. The appellate court determined that, based on the totality of the circumstances, there was a substantial basis for concluding that probable cause existed to issue the search warrant, citing established legal precedent on probable cause and warrant issuance.

This ruling means the evidence previously suppressed may now be admissible. The matter is remanded to the district court for further proceedings consistent with this opinion. This decision reinforces the standard for probable cause determination and the deference courts should give to the initial assessment of probable cause by the issuing magistrate. Legal professionals and law enforcement involved in search warrant applications and suppression hearings should review the court's reasoning regarding the totality of the circumstances and the definition of probable cause.

What to do next

Review the court's reasoning on probable cause and the totality of circumstances for search warrant applications.
Ensure all search warrant affidavits presented to magistrates meet the established probable cause standards.

Source document (simplified)

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March 9, 2026 Get Citation Alerts Download PDF Add Note

State Of Louisiana v. Edward D. Schertler, II

Louisiana Court of Appeal

Citations: None known
Docket Number: 2025 KW 1286
Precedential Status: Unknown Status
Opinion
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Cited By (0)
Summaries (0)
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Combined Opinion

STATE OF LOUISIANA
COURT OF APPEAL, FIRST CIRCUIT

STATE OF LOUISIANA NO. 2025 KW 1286
VERSUS

EDWARD D. SCHERTLER, IL MARCH 9, 2026
In Re: State of Louisiana, applying for supervisory writs, 17th

Judicial District Court, Parish of Lafourche, Nos.
630731, 630732.

BEFORE : MILLER, EDWARDS, AND FIELDS, JJ.

WRIT GRANTED. The district court’s ruling granting
defendant’s motion to suppress is reversed and this matter is
remanded to the district court for further proceedings. Probable
cause sufficient to issue a search warrant exists when the facts
and circumstances within the affiant’s knowledge and of which he
has reasonably trustworthy information, are sufficient to support
a reasonable belief that an offense has been committed and that
evidence or contraband may be found at the place to be searched.
State v. Casey, 99-0023 (La. 1/26/00), 775 So.2d 1022, 1027-28,
cert. denied, 531 U.S. 840, 121 S.Ct. 104, 148 L.Ed.2d 62 (2000).
The process of determining probable cause for the issuance of a
warrant does not involve certainties or proof beyond a reasonable
doubt, or even a prima facie showing, but rather involves
probabilities of human behavior, as understood by persons trained
in law enforcement and as based on the totality of the
circumstances. State v. Lurding, 2021-0430 (La. App. ist Cir.
12/22/21), 340 So.3d 97, 101, writ denied, 2022-00147 (La.
3/15/22), 334 So.3d 392. In this case, based on the totality of
the circumstances, we find there was a “substantial basis” for
concluding probable cause existed. Illinois v. Gates, 462 U.S.
213, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983); State v. Green, 2002-
1022 (La. 12/4/02), 831 So.2d 962, 969. After the fact scrutiny by
courts of the sufficiency of an affidavit should not take the form
of de novo review. Gates, 462 U.S. at 236, 103 S.Ct. at 2331.
Accordingly, the district court erred in granting the motion to
suppress.