Carly Doe v. Rayford - Legal Opinion
Summary
The Louisiana Court of Appeal granted a writ application in Carly Doe v. Rayford, remanding the case to the trial court. The appellate court's decision concerns the trial court's denial of a motion for appeal, specifically addressing the lack of a signed notice of intent and the setting of an appeal bond.
What changed
The Louisiana Court of Appeal, Fourth Circuit, granted a writ application in Carly Doe v. Rayford, remanding the matter to the trial court. The court's decision addresses the Relators' (defendants) writ application seeking review of the trial court's denial of their Motion for Appeal. The appellate court found the writ application lacked a signed notice of intent from the trial court and granted the writ solely to remand for the trial court to set a return date on the notice of intent. The underlying case involves a lawsuit filed by the Plaintiff/Respondent for damages arising from an alleged sexual assault, for which a default judgment on liability and a jury award of $3,605,000.00 were previously entered.
This ruling has immediate implications for the Relators' ability to pursue their appeal. While the writ is granted, the matter is sent back to the trial court to address procedural deficiencies related to the notice of intent for appeal. The trial court previously set the suspensive appeal bond at $3,605,000.00, the amount of the jury verdict. Legal professionals involved in this case must ensure all procedural requirements for appeals, including signed notices of intent and appropriate bond settings, are meticulously followed to avoid similar delays or denials.
What to do next
- Ensure all procedural requirements for appeals, including signed notices of intent, are met.
- Review trial court orders regarding the setting of appeal bonds.
Source document (simplified)
Jump To
Top Caption Disposition [Lead Opinion
by Judge Sandra Cabrina Jenkins](https://www.courtlistener.com/opinion/10808071/carly-doe-v-keithan-rayford-keegan-rayford-and-marcus-evans/about:blank#o1)
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.
March 12, 2026 Get Citation Alerts Download PDF Add Note
Carly Doe v. Keithan Rayford, Keegan Rayford, and Marcus Evans
Louisiana Court of Appeal
- Citations: None known
- Docket Number: 2026-C-0134
- Judges: Chief Judge Roland L. Belsome; Judge Rosemary Ledet; Judge Sandra Cabrina Jenkins
Disposition: Writ Granted and Remanded
Disposition
Writ Granted and Remanded
Lead Opinion
by Judge Sandra Cabrina Jenkins
CARLY DOE * NO. 2026-C-0134
VERSUS *
COURT OF APPEAL
KEITHAN RAYFORD, *
KEEGAN RAYFORD, AND FOURTH CIRCUIT
MARCUS EVANS *
STATE OF LOUISIANA
APPLICATION FOR WRITS DIRECTED TO
CIVIL DISTRICT COURT, ORLEANS PARISH
NO. 2022-03726, DIVISION “I-14”
Honorable Lori Jupiter, Judge
Judge Sandra Cabrina Jenkins
(Court composed of Chief Judge Roland L. Belsome, Judge Rosemary Ledet,
Judge Sandra Cabrina Jenkins)
Corrie Gallien
Gallien Law, PLLC
1030 Lafayette Street, Suite 12
Lafayette, LA 70501
COUNSEL FOR RELATORS
William Most
Hope Phelps
Caroline Gabriel
Most & Associates
201 St. Charles Avenue, Ste 2500, #9685
New Orleans, LA 70170
COUNSEL FOR RESPONDENT
WRIT GRANTED AND REMANDED
MARCH 12, 2026
SCJ
RLB
RML Relators, Keithan Rayford, Keegan Rayford, and Marcus Evans seek review
of the trial court’s January 22, 2026 judgment denying Relators’ Motion for
Appeal. Relators’ writ application lacks a signed notice of intent from the trial
court. For the reasons that follow, Relators writ application is granted for the
limited and sole purpose of remanding this matter to the trial court to set a return
date on Relators’ notice of Intent.
FACTUAL AND PROCEDURAL HISTORY
Plaintiff/Respondent filed suit against Defendants/Relators on April 2, 2022,
for damages arising out of an alleged sexual assault.1 On April 3, 2024, the trial
court granted Respondent’s motion for sanctions and a default judgment on the
issue of liability. A trial on damages took place on March 24, 2025, and the jury
awarded Respondent $3,605,000.00.
Relators alleged their trial counsel had been disbarred; and as a result, they
did not receive a copy of the judgment until a copy was e-mailed to them by
Respondent’s counsel on June 27, 2025. Relators’ current counsel filed a Motion
1 The underlying allegations of the sexual assault or the merits of Respondent’s complaint are not
relevant to this writ disposition.
1
for Appeal on September 23, 2025, which the trial court fixed for hearing on
November 20, 2025. In the interim, on September 27, 2025, Relators filed an
Amended Motion for Suspensive Appeal, which requested the court set a
reasonable suspensive appeal bond. The trial court granted the amended motion on
September 29, 2025, setting the appeal bond at $3,605,000.00, the amount of the
jury verdict. At the November 20, 2025 hearing on the original Motion to Appeal,
Relators requested that they be permitted to file a devolutive appeal without bond.
Relators emphasized that they had filed a Motion for Nullity in a new lawsuit to
invalidate the default judgment. On January 22, 2026, the trial court denied
Relators’ Motion for Appeal.2
On February 20, 2026, Relators filed the present writ application seeking
review of the trial court’s January 22, 2026 judgment. Relators’ writ application
failed to include the trial court’s order setting a return date pursuant to Uniform
Rules, Courts of Appeal, Rule 4-5. Accordingly, this Court ordered Relators to
supplement the writ application with same. In response, Relators filed a “Motion
to Accept Writ Application Without Return Date and to Fix Return Date.” In the
motion, Relators attached their February 4, 2026 Notice of Intent seeking review of
the trial court’s January 22, 2026 judgment. Relators also attached a February 10,
2025 order from the trial court stamped “DENIED” with the handwritten note, “No
interlocutory judgments exist. This case has been adjudicated to a final judgment.”
Thus, the trial court refused to set a return date. We find this was error.
2 In the trial court’s reasons for judgment, the court referenced in its footnote 3 that “Defendants
have noted that this Court granted their Amended Motion for Suspensive Appeal, filed September
27th, 2025, on September 29th, 2025. However, upon further examination, that motion was
granted in error for the reasons stated herein.”
2
DISCUSSION
In accordance with La. C.C.P. art. 1841, the trial court’s January 22, 2026
ruling denying Relators’ second Motion for Appeal was an interlocutory
judgment.3 In particular, the judgment did not determine the merits of the
underlying complaint. As such, because Relators filed a timely Notice of Intent,
the trial court was required to set a return date. Uniform Rules, Courts of Appeal,
Rule 4-3 provides:
The judge who has been given notice of intention as provided by
Rule 4-2 shall immediately set a reasonable return date within
which the application shall be filed in the Court of Appeal. The
return date in civil cases shall not exceed 30 days from the date of
notice of the judgment, as provided in La. C.C.P. art. 1914. In
criminal cases, unless the judge orders the ruling to be reduced to
writing, the return date shall not exceed 30 days from the date of the
ruling at issue. When the judge orders the ruling to be reduced to
writing in criminal cases, the return date shall not exceed 30 days
from the date the ruling is signed. In all cases, the judge shall set an
explicit return date; a Court of Appeal shall not infer a return date
from the record. (Emphasis added).
Upon proper showing, the trial court or the Court of Appeal may
extend the time for filing the application upon the filing of a motion
for an extension of the return date by the applicant, filed within the
original or an extended return date period. An application not filed in
the Court of Appeal within the time so fixed or extended shall not be
considered, in the absence of a showing that the delay in filing was
not due to the applicant's fault. The application for writs shall contain
documentation of the return date and any extensions thereof; any
3 Louisiana Code of Civil Procedure art. 1841 provides as follows:
A judgment is the determination of the rights of the parties in an action and may
award any relief to which the parties are entitled. It may be interlocutory or final.
A judgment that does not determine the merits but only preliminary matters in the
course of the action is an interlocutory judgment.
A judgment that determines the merits in whole or in part is a final judgment.
3
application that does not contain this documentation may not be
considered by the Court of Appeal.
CONCLUSION
Accordingly, based on the foregoing, we grant Relators’ writ application for
the limited and sole purpose of remanding the matter to the trial court to set a
return date in accordance with Uniform Rules, Courts of Appeal, Rule 4-3.
WRIT GRANTED AND REMANDED
4
Related changes
Source
Classification
Who this affects
Taxonomy
Browse Categories
Get Government alerts
Weekly digest. AI-summarized, no noise.
Free. Unsubscribe anytime.
Get alerts for this source
We'll email you when Louisiana Court of Appeal publishes new changes.