# Opposition Brief — Recall '92, Inc. v. Edwards > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386005_1732%3A2 ## Record - **Collection:** Supreme Court brief - **Document type:** Opposition Brief - **Published:** January 1, 1994 - **Citation:** 511 U.S. 1017 ## Text , | Ramm oor, We No. 93-1062 FIFFYNn = In The Supreme Court of the United States October Term, 1993 o RECALL ’92, INC., et al., Petitioners, versus EDWIN W. EDWARDS, Governor of the State of Louisiana, et al., Responden ts. . On Petition For Writ Of Certiorari To The United States Court Of Appeals For The Fifth Circuit 6 RESPONDENTS’ BRIEF IN OPPOSITION TO THE PETITION FOR WRIT OF CERTIORARI ¢ RICHARD P. Igvous Attorney General State of Louisiana James M. Ross* Assistant Attorney General P. O. Box 94005 Baton Rouge, Louisiana 70804-9005 (504) 342-7013 Roy A. MOnGruE, JR. Assistant Attorney General P. O. Box 94005 Baton Rouge, Louisiana 70804-9005 (504) 342-7013 AnaciE R. LAPLact Assistant Attorney General P. O. Box 94005 Baton Rouge, Louisiana 70804-9005 (504) 342-7013 + Counsel of Record Counsel for Respondents COCKLE LAW BRIEF PRINTING CO, (800) 225-6964 OR CALL COLLECT (402) 342-2831 TABLE OF CONTENTS Page pr rere ry rrr os Pew rer re ee REE er re rrr ee ae re ii Citations of Opinions and Judgments Below ....... 1 IRE EES EEF NS ET OAS CP eT Ca 2 ee ee cou ae abe eee eeu eeed 2 EY Oe PIII o's. 6'c a 6 bee cen kecdbveesscunes 9 IEE 6h vivnb 64 Se ele were ecetc necekdesseveesenness 11 (Ec ETRE Ae eH SN aN a aD ee 17 ii TABLE OF AUTHORITIES Page CASES Burson v. Freeman, __ U.S. __, 112 S.Ct. 1846, 119 Ro Oo. | rrr arte re ne Se passim Calchera v. Procarione, 805 F.Supp. 716 (E.D. Wisc. NOIR ogo vv btbh 0 ndedece eee 5 CBS, Inc. v. Smith, 681 F.Supp. (1204 N.D. Ga. 1) PPT errerErrcerre vers rr rr er, kpc s 9 City of Houston v. Hill, 482 U.S. 451, 107 S.Ct. 2502 CSE cc cc dees vande eee Oo rere eee eee 17 Clean-Up ‘84 v. Heinrich, 759 F.2d 1511 (11th Cir. 5) A rrr rar as Pe Sy 5 Daily Herald v. Munro, 838 F.2d 380 (Ca. 1988)........ 9 Longo v. U.S. Postal Service, 953 F.2d 790, 983 F.2d 9 (Joel Ge. 1982) oe ve ade ccvaeyusa ss eee 16 Mills v. Alabama, 384 U.S. 214, 86 S.Ct. 1434, 16 LOéd. 640968... ce eee 13 NBC v. Cleland, 697 F.Supp. (1204 N.D. Ga. 1988)..... 9 U.S. v. Kokinda, 497 U.S. 720, 110 S.Ct. 3115, 111 oS” es ee eerer err rere er he tr ye ere 16 STATUTE SARS. 103068. ...0 sithincesseieeee eee passim No. 93-1062 ¢ In The Supreme Court of the United States October Term, 1993 7 RECALL '92, INC., et al., Petitioners, versus EDWIN W. EDWARDS, Governor of the State of Louisiana, et al., Respondents. S On Petition For Writ Of Certiorari To The United States Court Of Appeals For The Fifth Circuit « RESPONDENTS’ BRIEF IN OPPOSITION TO THE PETITION FOR WRIT OF CERTIORARI + CITATIONS OF OPINIONS AND JUDGMENTS BELOW The opinions and judgments of the United States District Court for the Middle District of Louisiana and the United States Court of Appeals for the Fifth Circuit are contained in Petitioners Appendix to its Petition for a Writ of Certiorari. All references by Respondents in this opposition brief will be to those decisions contained in Petitioner’s Arpendix. INTRODUCTION The State of Louisiana through the named defen- dants, Edwin W. Edwards, Governor, Richard P. leyoub, Attorney General and W. Fox McKeithen, Secretary of State submit this Brief in Opposition to the Petition for Writ of Certiorari in order to point out material misstate- ments or omissions of fact or law set forth in the petition, in accord with this Court’s Rule 15 as well as to present the state’s arguments for denying the petition for writ of certiorari. Respondents will address these specific items of perceived misstatement or omission prior to the argu- ment for the State’s position for denying the petition. + STATEMENT OF THE CASE This case involves a First Amendment challenge to Louisiana’s electioneering law, LSA-R.S. 18:1462 which prohibits all electioneering activity as well as to prohibit the display of political signs, pictures, advertising and the distribution of campaign cards, or campaign literature of any description whatsoever, with a 600 foot radius of the entrances to polling places on election and absentee voting days in Louisiana. Relying on the following this Court’s decision in Burson v. Freeman, U.S. __, 112 S.Ct. 1846, 119 L.Ed.2d 5 (1992), the United States District Court found the chal- lenged statute constitutional as creating a campaign-free zone around polling places and that the statute applied to both issues and parties whether or not they were on the ballot. See Appendix G. The Fifth Circuit Court of eo Appeals affirmed that decision, see Appendix B. Peti- tioners now ask this Court to reverse and declare the statute unconstitutional, alleging two grounds, “(1) whether, consistent with the First Amendment, a state can proscribe non-ballot related political speech in areas outside polling places on election days, and (2) at what measurable distance from the polls does the govern- ment’s restriction of political speech become an imper- missible burden on First Amendment rights. Petition p. 4. It should be noted at the outset that the statute does not bar “political speech” but prohibits the activities set forth in the statute as interpreted by the United States District and Appellate Courts and the Louisiana Supreme Court on certification from the Fifth Circuit, Schirmer, et al. v. Edwards, et al., No. 92-CQ-2829, Appendix E. All of these Courts correctly decided that LSA-R.S. 18:1462 did pro- hibit the solicitation of signatures in a recall petition and that the statute applied to that activity. MISSTATEMENTS OR OMISSIONS OF LAW AND FACT First, the challenged statute is incompletely set out, in the petition, in that sections B through F are omitted, p. 3 Appendix A, these sections were not challenged. Section B, set out below, is however, vital, in that it exempts private property, not used as a polling place, from the prohibition on the placing of political signs and pictures. This important section distinguishes two cases relied on by petitioner in the application: LSA-R.S. 18:1462 A. Except as otherwise provided by law, it shall be unlawful for any person, between the hours of 6:00 a.m. and 9:00 p.m., to perform or cause to be performed any of the following acts within any polling place being used in an elec- tion on election day or within any place wherein absentee voting is being conducted, or within a radius of six hundred feet of the entrance to any polling place being used in an election on elec- tion day or any place wherein absentee voting is being conducted: (1) To solicit in any manner or by any means whatsoever any other person to vote for or against any candidate or proposition being voted on in such election. (2) To remain within any such polling place or place wherein absentee voting is being con- ducted or within a radius of six hundred feet of the entrance of any such polling place, except when exercising the right to vote, after having been directed, in writing, by an election com- missioner or law enforcement officer to leave | the premises or are of a polling place or after having been directed, in writing, by a registrar | or deputy registrar to leave the place wherein absentee voting is being conducted. ! (3) To hand out, place, or display campaign cards, pictures, or other campaign literature of any kind or description whatsoever. (4) To place or display political signs, pictures, or other forms of political advertising. B. The provisions hereof shall not apply to the placing and displaying, either by the owner, ee lessee, or lawful occupant thereof, or with the consent of such owner, lessee or occupant, of political signs or pictures on private property which is not being used as a polling place. At p. 15 of the petition, it is alleged that there is a conflict between the 5th Circuit’s decision in this case and the 11th circuit’s decision in Clean-Up ‘84 v. Heinrich, 759 F.2d 1511 (11th Cir. 1985). Initially respondents submit that Clean-Up ‘84 was decided seven (7) years prior to the Court’s landmark decision in Burson v. Freeman, supra (1992) and that Burson represents the rule in the United States and that there is therefore no conflict. Furthermore, Clean-Up is distinguished by the fact that the prohibition contained in the Florida statute did not exempt private property as does Louisiana’s, see Section B above. Petitioners also cite the post Burson case of Calchera v. Procarione, 805 F. Supp. 716 (E.D. Wisc. 1993) which found Wisconsin’s statute prohibiting campaign speech within 500 feet of the polls unconstitutional. In Calchera, the Wisconsin statute did not exempt private property and therefore prohibited the placement of political signs on private property within the 500 foot radius. The Court was uncertain as to the validity of the 500 foot zone, see Calchera, p. 719, commenting on Burson, “This language might suggest that the plurality would have no problem with even a 500 foot boundary as prescribed in Section 12.03(2).” What the Wisconsin Court had problems with and what was the reason for decision, the State submits, was the private property prohibition, as follows, “This is not a case where the legislature is regulating expression in a public forum; section 12.03 with its sweeping zone of protection, pro- hibits individual homeowners from expressing their political views on their own property. p. 720” The Louisiana statute exempts private property, LSA-R.S. 48:1462 B. In light of the above there is no conflict in the Cir- cuits and the later District Court case is clearly distin- guishable from the petition herein. The state also points out that the companion case relied on by petitioner at p. 12 & 13, State of Louisiana v. Schirmer, Appendix H is not a final judgment and is presently docketed in the Louisiana Supreme Court as docket No. 93-KA-2631. This is a crimi- nal misdemeanor case and the State 1s appealing the judgment on the motion to quash the bill of information. Second. Petitioners in brief, at p. 21 state that Louisiana’s restricted zone around polling places dates only from 1960. This is incorrect. A restricted zone or barrier around polling places in Louisiana’s statutes dates from 1894. A listing of the acts of the legislature incorporating some barrier is of record in this case and is listed below along with the size of the zone in that act. (1) Act 181 of 1894, Section 17 created a 15 foot barrier in front of each polling place and a 10 foot barrier to its side. (2) Act 137 of 1896, Section 41 prohibited any person from obstructing, hindering or delaying any voter on his way to a polling place and provided for a 6 foot barrier. (3) Act 49 of 1906, Section 37, prohibited any person from buying, selling or offering anything of value to a voter, intimidating, ae Re ET (4) (5) (6) (7) (8) (9) by threat or promise, any voter for the pur- pose of influencing his vote. It also pro- vided for at least a six foot barrier. In 1914, Act 277 increased the barrier from six feet to fifty feet. Act 97 of 1922 continued the 50 foot guard rail, and prohibited anyone within the bar- rier, except commissioners, watchers, and voters actually voting. Also provided a penalty for any person who bought any vote or intimidated any voter. In 1960, Act 40 increased the barrier around the polling place to 600 feet. However, Act 221 of 1960 also increased the barrier to 300 feet and specifically repealed Act 40 of 1960. Act 40 of 1960 was again repealed by Act 32 of 1962. Act 221 of 1960 enacted LSA-R.S. 18:1534 with a 300 foot barrier. It also provided for candidates to place their campaign cards or sample ballots on a table near the entrance to the polling place, so that a voter could select one if he so desired, “free from the influence, solicitation or suggestion of any kind”. Act 493 of 1972 amended LSA-R.S. 18:1534 to prohibit any person from polling or dis- playing campaign cards or sample ballots near the entrance to any polling place, thereby repealing the language in Act 221 of 1960. In 1980, Act 180 increased the barrier around polling places to 600 feet. (repealed LSA-R.S. 18:1534). Louisiana has a 100 year history of providing some size of restricted zone around the voting area that was found necessary in Burson, to secure the state’s compel- ling interest in preventing voter intimidation and election fraud, Burson p. 1855. Third. Petitioners at p. 10, allege that the state did not present concrete evidence for the need of the 600 foot barrier enacted in 1980 by Act 180. This is incorrect. The record is replete with testimony proving the fact that the legislature considered the 300 foot barrier insufficient and raised the barrier to 600 feet for that reason. Representa- tive Charles Lancaster, the author of Act 180 testified that the 300 foot limit “was not effective in having a polling place that was totally free from political influence on election days.” (Transcript, Volume 3, p. 145). Representa- tive Joe Accardo, Chairman of the House and Govern- mental Affairs Committee of the Louisiana House of Representatives, testified that he and that committee sup- ported legislation increasing the distance from 300 feet to 600 feet in LSA-R.S. 18:1462. He stated, “I supported the legislation, . . . because in the District I live in, the 300 foot limit was very often not enough distance to keep people who were engaged in political activities from inter- secting the voters who were going to the polls. Very often the 300 foot limit was — the parking lots were outside the 300 foot limit. Very often people parked on the street to get to the polling places and there were instances where there was political activity going on by various candidates and their supporters trying to talk to voters as they walked to the polls or try to get to the polls. (Transcript, Volume 3, p. 180). The record is clear that the Louisiana legislature carefully considered the 300 foot limit and found it to be inade- quate, then increased that limit to 600 feet to insure that Louisiana voters would be free of interference, fraud, intimidation and confusion at the polls on election day. Fourth. Petitioners in brief st p. 18 make the statement that exit polling “is at least as intrusive and disruptive as the activity proposed by petitioner in the instant case which is the solicitation of signatures for a recall peti- tion.” Petitioners attempt to rely on exit polling and media interviewing cases, namely, Daily Herald Company v. Munro, 838 F.2d 380 (9th Cir. 1988); NBC v. Cleland, 697 F.Supp 1204 (N.D. GA. 1988); CBS Inc. v. Smith, 681 F.Supp 794 (S.S. Fla. 1988). These cases are not applicable to this question. Exit polling is news gathering activity undertaken after the voter has voted, not political activ- ity, such as an attempt to solicit signatures on a recall petition or an attempt to campaign for a candidate. , The foregoing is submitted in accord with Rule 15. The following is the state’s position on why the Judg- ments of the District Court and Court of Appeal are correct and that the petition for writ of certiorari should be denied. SUMMARY OF THE ARGUMENT LSA-R.S. 18:1462 prohibits the political activity listed therein including speech in the form of campaigning within 600 feet of a polling place on election day and during absentee voting. The decisions of the District Court and the Fifth Circuit Court of Appeals upholding 10 the constitutionality of that statute were mandated by this Supreme Court’s recent decision Burson v. Freeman, 112 S.Ct. 1846 (1992). It is respondents’ position that each state has the right to provide a campaign free zone around its polling places. That each state must rely on its own experience in deciding what size zone it should have. That Louisiana, like Tennessee in Burson, has pro- vided such election laws for its citizens for approximately 100 years. That the Louisiana experience as evidenced by its legislative acts indicates that the 600 foot zone is deemed necessary for this purpose. That the statute is narrowly drawn in that it restricts First Amendment rights only while the polls are open on one or two days every years or so and at absentee voting places and that all other places, times and manner of political speech is left open and unrestricted. That this statute is necessary in order to provide Louisiana’s citizens free and unen- cumbered access to the polls so that they may exercise their right to vote freely and without interference, intim- idation or confusion. It is the State’s position that it is constitutional for the statute to prohibit non-ballot related activity such as the recall petition herein and without such a prohibition the statute would be virtually unenforceable. It is further respondents’ position that the statute, as found by the District Court, Court of Appeal and Louisi- ana Supreme Court on certification from the Fifth Circuit, prohibited in section A(3) & (4) the recall petition activity sought to be engaged in by petitioners. There is simply 11 no necessity to grant the writ to clarify Burson for its teachings are clear. ARGUMENT The basis of the lower court’s decisions upholding the constitutionality of Louisiana’s statute is this Court's decision in Burson recognizing the state’s right to provide a campaign free zone around polling places on election day. The most powerful arguments for not granting the writ and for upholding the statute’s constitutionality are contained in Justice Blackmun’s decision in Bursom. In that Burson settled the issues raised therein, Petitioner’s claim that only two questions remain open for decision in this case. First, can Louisiana proscribe political activity, campaigning or politicking not related to items on the election ballot and second, is Louisiana’s 600 foot cam- paign-free zone so impermissibly large as to render it unconstitutional. WHAT SIZE ZONE IS PERMITTED? Petitioners argue that the real question remaining is, at what measurable distance from the polls does the government's restriction on campaign activity become an impermissible burden on First Amendment rights. The answer to this question is again provided by Burson indi- rectly and is: Whatever distance that is deemed necessary by the State’s citizens through their elected representa- tives in order to insure that the polls will be free from accumsan 12 voter intimidation, interference, election-fraud and con- fusion, until that zone interferes with First Amendment rights not related to the polling place. Respondents stress and Burson states that the autho- rized goa! of these statutes is to have a campaign free polling place. They are not designed to create difficulties for political activity at the polls, they are designed to eliminate it. Therefore, whatever distance that is neces- sary in each state’s judgment, to accomplish the desired end is appropriate until that distance becomes unreason- able. New Hampshire had ten feet, Louisiana has 600 feet, Kentucky and Wisconsin have 500 feet, thirty-eight states have established campaign-free zones of 250 feet or less, Petition, p.7 None of these states are right or wrong. They simply have different judgments. This Court in Burson has upheld Tennessee’s 100 foot zone. This question was addressed in Burson beginning at 112 S.Ct. 1856 as fol- lows: “The real question is how large a restricted zone is permissible or sufficiently tailored. . . . Furthermore, because a government has such a compelling interest in securing the right to vote freely and effectively, this Court never has held a State “to the burden of demonstrating empiri- cally the objective efforts on political stability that [are] produced” by the voting regulation in question. Citing Munro v. Socialist Workers Party, 479 U.S. 189, 195 107 S.Ct. 533, 537, 93 L.Ed. 2d 499 (1986). ... Beginning at p. 1857 Burson continued, 13 “Thus, requiring proof that a 100-foot boundary is perfectly tailored to deal with voter intimida- tion and election fraud would necessitate that a State’s political system sustain some level of damage before the legislature could take correc- tive action. Legislatures, we think, should be permitted to respond to potential deficiencies in the electoral process with foresight rather than reactively, provided that the response is reason- able and does not significantly impinge on con- stitutionally protected rights.” Id., at 195-196, 107 S.Ct., at 537-38 (emphasis added). “We do not think that the minor geographic limitation prescribed by § 2-7-111(b) constitute such a significant impingement. Thus, we sim- ply do not view the question whether the 100- foot boundary line could be somewhat tighter as a question of “constitutional dimension.” Of course, at some distance from the polls, a campaign- free zone would be unconstitutional. Burson again addressed this, at p. 1857, “At some measurable distance from the polls, of course, governmental regulation of vote solicita- tion could effectively become an impermissible burden akin to the statute struck down in Mills v. Alabama, supra.” Mills v. Alabama, 384 U.S. 214, 86 S.Ct. 1434, 16 L.Ed. 484 (1966) struck down a law that made it a crime for a newspaper editor to publish an editorial election day urging readers to vote in a particular way. Louisiana’s 600 foot zone, and the states at 500, 250 or less are not akin to Mills which involved no distance but was an outright ban on political speech. Louisiana does not have to draw the perfect distance. The statutory history reflects that in 14 1980 it considered 300 feet inadequate and amended the statute to increase the zone to 600 feet to accomplish the constitutionally protected purpose. The perfect distance may be 100, 200, 300, 400 or Hawaii's 1000 foot zone, the country’s largest. In New Hampshire’s judgment, 10 feet is adequate. In the absence of a federal election law on the subject, each state has the right to carve out the campaign free zone that it deems necessary. Louisiana’s zone is not impermissibly large. Burson answers the ques- tions raised in petitioner’s writ application and the peti- tion should be denied. THE STATE CAN PROSiBIT NON-BALLOT RELATED CAMPA‘‘;* ACTIVITY IN THE CAMPAIGN-FREE ZONE. The answer to this remaining issue alleged by peti- tioner is clear to the effect that the statute may ban non- ballot related activity. Any other answer would render the constitutionally authorized zone meaningless for it would allow all other campaign activity or politicking other than ballot related activity. This would open the environs of the polling places to candidates seeking the same captive audience that the recall drive sought. Com- mon sense teaches, what better place to find voters than at a polling place. Office seekers facing upcoming elec- tions would descend on polling places to campaign while the voters voted. Some might even campaign for allies on that day’s ballot until they were required to leave. Those in favor of a recall would compete for the voters attention with those opposed to the recall creating the kind of political free for all that 100 years of state legislative ee ET 15 history has sought to prevent, for one day (14 hours) and at one place. This would unquestionably increase voter interference, intimidation, election fraud and confusion. All the lower Courts in this case, including the Louisiana Supreme Court concurred that the statute banned the non-ballot related activity engaged in by petitioner. They found that sections (3) and (4) of LSA-R.S. 18:1462 prohib- ited the recall signs, stands and paraphernalia used by petitioner. These sections are set out below and appear at petitioner's Appendix A. LSA-R.2. 18:1462 (3) To hand out, place or display campaign cards, pictures, or other campaign litera- ture of any kind or description whatsoever. (4) To place or display political signs, pictures, or other forms of political advertising. The Fifth Circuit held that Louisiana’s statute banning all political activity described therein was even more defens- ible than the Tennessee statute upheld in Burson and would have answered some of Justice Stevens concerns expressed in his dissent in Burson. In any event, it is clear that without the total ban in the campaign-free zone the statute would be potentially useless. The Fifth Circuit in this case, reported at 2 F.3d 117, held correctly at p. 123, “Accordingly, we find that a total ban on poli- ticking within the campaign-free zone is not overboard. In fact, the total ban in the present context is the most defensible position. The state has a compelling interest in protecting its voters and the proffered reasons given by the legisla- ture demonstrate a reasonable compromise to 16 the problems that necessitated the campaign- free zone in the beginning.” That the states or the federal government have the constitutional power to ban campaign activity or solicita- tion activity in certain public places is well settled by recent decisions in the following cases. In U.S. v. Kokinda, 497 U.S. 720, 111 L. Ed. 571, 110 S.Ct. 3115 (1990) this Court upheld a postal service regulation prohibiting solicitation on postal service premises and the distribut- ing of literature on a sidewalk near a post office entrance. Of particular interest to this case is the Kokinda Court's discussion of the nature of solicitation at p. 3123 citing United States v. Belsky, 799 F.2d 1485 (11th Cir. 1986), “ ‘Soliciting funds in an inherently more intru- sive and complicated activity than is distribut- ing literature.’ . . . [it is] more intrusive and intimidating than an encounter with a person giving out information.” In the instant case, petitioners desired to set up recall stands near the polling places to have access both to the captive audience of those desiring to vote and also and even more intrusive, the ability to have those who had voted be able to return to the polls and check their registration signatures while others were attempting to vote. In Longo v. U.S. Postal Service, 953 F.2d 790 (2nd Cir. 1992) the Second Circuit held that a postal service regula- tion prohibiting campaigning for election to public office on postal service property was constitutional. On remand after this Court’s Burson decision, the Longo court changed its rationale but reached the same decision, namely that the postal service could prohibit campaign- ing on postal service property. This is a year round ban. a 17 The electioneering statute is a one day ban and is as narrowly drawn as is necessary to accomplish the desired end, which is a campaign free polling place. The Fifth Circuit and the District Court were correct in holding that the statute, in banning the non-ballot related activity the subject of this case, is constitutional. ¢ CONCLUSION This Court in Burson v. Freeman, supra, has answered all of the questions presented in petitioner’s writ applica- tion. In order to further its constitutionally protected compelling interest in preventing voter intimidation, elec- tion fraud, interference and confusion, Louisiana has established, after 100 years of statutory history, a 600 foot campaign-free zone around the polls on election day and absentee voting days. All fifty states have such zones. They are narrowly drawn as to the distance and most importantly time, namely one or two days. The statute bans the non-ballot related activity listed therein which included the recall petition, the subject of this case. This is a petition that simpiy does not need to be granted because this case was in essence, decided by this Honor- able Court in 1992 in Burson v. Freeman. A quote from the petition for certiorari best expresses the philosophical differences between petitioner and respondents. It is found at page 18 and cites a phrase from this Court’s decision in City of Houston v. Hill, 482 U.S. 451, at 452, 107 S.Ct. 2502 (1987) as follows, “a certain-amount of expressive disorder is inevitable in a 18 free society and must be protected if freedom is to sur- vive.” Both this Supreme Court in Burson and the legisla- tures of fifty states have determined that this “expressive disorder” shall not interfere with voting at or near the polling places on election day. For the above reasons, Respondents ask that this Honorable Court deny the petition for Writ of Certiorari in this matter. Respectfully submitted, RicHARD P. Ievous Attorney General State of Louisiana James M. Ross* Assistant Attorney General P. O. Box 94005 Baton Rouge, Louisiana 70804-9005 (504) 342-7013 Roy A. Monarue, Jr. Assistant Attorney General P. O. Box 94005 Baton Rouge, Louisiana 70804-9005 (504) 342-7013 Ancie R. LAPLAcE Assistant Attorney General P. O. Box 94005 Baton Rouge, Louisiana 70804-9005 (504) 342-7013 "Counsel of Record Counsel for Respondents --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386005_1732%3A2. Public record. Not legal advice.