LIVINGSTON, La. — The Louisiana Supreme Court has ordered the Livingston Parish Government to pay $37,042.26 in attorney fees to the former tourism board member who sued over his removal, ruling that the parish council violated the state's Open Meetings Law during two meetings in March 2024.
The April 9 ruling resolves the final question in the case of Harold Marcell Parker Jr. v. Livingston Parish Government: who pays the legal bill. The court found that the parish government, not individual Councilman Joseph Erdey, bears responsibility for the fees. Erdey was assessed a $500 civil penalty for his knowing and willful participation in the violations but cannot be held personally liable for the plaintiff's attorney costs.
The case dates to the earliest days of the current council's term. At its March 14, 2024, regular meeting, the council unanimously approved Erdey's motion to remove Parker from the Livingston Parish Convention and Visitors Bureau and replace him with Chris Levy, Erdey's ex-wife. The move was one of several committee appointments approved as the new council and administration began their term.
Parker, who had been elected chairman of the bureau the month before, challenged his removal. His attorney, Tom Easterly, argued that the council lacked authority to remove Parker and that the agenda language used to justify an executive session discussion of the matter cited his "character, professional competence, physical and/or mental health" without basis.
Court records show that Erdey himself acknowledged before the council entered executive session that there were no character or fitness issues with Parker and that he wished to discuss only the removal itself. The council proceeded into closed session anyway.
A trial court in the 21st Judicial District found that the council violated Open Meetings Law in two respects: the agenda item lacked the "reasonable specificity" required by state law, and the council improperly addressed Parker's removal in executive session. Both the parish government and Erdey were initially ordered to pay Parker's legal fees.
Erdey appealed the attorney fee portion of the judgment. The Supreme Court, in a per curiam opinion, sided with him on that narrow question, holding that under Louisiana law, attorney fee awards authorized by R.S. 42:26 may only be assessed against the public body found to have violated the Open Meetings Law, not against individual members. Individual members who knowingly participate in violations are subject only to the $500 civil penalty provided under R.S. 42:28.
Two justices, Guidry and Penzato, recused themselves from the case.
Parish President Randy Delatte released a statement Friday acknowledging the ruling and drawing a line between his administration and the council's actions. He noted that under the parish's Home Rule Charter, agenda language and executive session procedures fall under the council's responsibilities.
Delatte said the parish will comply with the court's decision and that his administration will work with the council to ensure future compliance with state law.
The $37,042.26 tab will be paid with public funds.
The ruling is the second time in recent months that a Livingston Parish governing body has been found in violation of Open Meetings Law. In October 2025, the Livingston Parish Library Board settled a separate lawsuit filed by Attorney General Liz Murrill alleging the board violated the law when it terminated its executive director during a July 2025 meeting. That settlement required board members to undergo open meetings training but carried no financial penalty.
