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State v. McEwen

Supreme Court of Louisiana
Apr 3, 1987
504 So. 2d 817 (La. 1987)

Summary

In State v. McEwen, 504 So.2d 817 (La. 1987), the Court held that the initial offense report "should included all information obtained in the initial investigation of the complaint, especially when the initial investigation following a complaint results in the requesting party's arrest."

Summary of this case from State v. Campbell

Opinion

No. 87-KK-0478.

April 3, 1987.

APPEAL FROM CRIMINAL DISTRICT COURT, ORLEANS PARISH, STATE OF LOUISIANA.


Granted. The intent of La.R.S. 44:3A(4) is to declare that the entire initial report of the investigation following a complaint constitutes a public record subject to discovery. The reporting officer may not defeat the purpose of the statute by including only selective information in the initial report and placing the remainder of the information obtained in the initial investigation in a separate supplemental report. The initial report should include all information obtained in the initial investigation of the complaint, especially when the initial investigation following a complaint results in the requesting party's arrest.

Accordingly, the case is remanded to the trial court to conduct an evidentiary hearing to determine what information was uncovered in the initial investigation and to order the officer to file an amended initial report containing that information, as required by the statute.


Summaries of

State v. McEwen

Supreme Court of Louisiana
Apr 3, 1987
504 So. 2d 817 (La. 1987)

In State v. McEwen, 504 So.2d 817 (La. 1987), the Court held that the initial offense report "should included all information obtained in the initial investigation of the complaint, especially when the initial investigation following a complaint results in the requesting party's arrest."

Summary of this case from State v. Campbell

In McEwen the court condemned the practice of putting limited information in a document entitled "initial report" and placing the remainder in a "supplemental report", all information in both documents resulting from the same initial investigation of a complaint.

Summary of this case from State v. Huntley
Case details for

State v. McEwen

Case Details

Full title:STATE OF LOUISIANA v. ALBERT McEWEN

Court:Supreme Court of Louisiana

Date published: Apr 3, 1987

Citations

504 So. 2d 817 (La. 1987)

Citing Cases

State v. Campbell

The Supreme Court has since consistently interpreted La.R.S. 44:3 broadly. In State v. McEwen, 504 So.2d…

State v. Washington

However, the reporting officer or officers may not defeat the purpose of the statute by including only…