STATE OF LOUISIANA v. WANDA LEDET (2026)

Court of Appeal of Louisiana, Fourth Circuit.

STATE OF LOUISIANA v. WANDA LEDET

NO. 2026-K-0315

Decided: May 05, 2026

(Court composed of Judge Daniel L. Dysart, Judge Joy Cossich Lobrano, Judge Karen K. Herman)

JASON ROGERS WILLIAMS District Attorney Parish of Orleans BRAD SCOTT Chief of Appeals Parish of Orleans PATRICIA AMOS Assistant District Attorney Orleans Parish District Attorney's Office 619 S. White St. New Orleans, LA 70119 COUNSEL FOR RELATOR - THE STATE OF LOUISIANA JAMES H. MILLER Orleans Public Defenders 2601 Tulane Avenue, Ste. 700 New Orleans, LA 70119 COUNSEL FOR RESPONDENT - DEFENDANT

Relator, the State of Louisiana, seeks expedited supervisory review of the trial court's May 4, 2026 ruling, which denied its motion to continue trial.

The grand jury indicted Defendant, Wanda Ledet, on one count of first degree murder (in violation of La. R.S. 14:30) and one count of resisting an officer (in violation of La. R.S. 14:108). A judge trial on the matter is set for May 6, 2026. Defendant tendered the expert report of Dr. Sarah Deland regarding Defendant's not guilty by reason of insanity plea on April 27, 2026. On April 28, 2026, the State filed a motion to continue the trial date based on the untimely filing of the expert report and arguing that certain medical records and interviews supporting Dr. Deland's opinion were not provided to the State in discovery.

“A motion for continuance, if timely filed, may be granted, in the discretion of the court, in any case if there is good ground therefor.” La. C.Cr.P. art. 712. “[T]he decision to grant or deny a motion for continuance rests with the sound discretion of the trial judge, and a reviewing court will not disturb such a determination absent a clear abuse of discretion.” State v. Cinquemano, 2018-0532, p. 5 (La. App. 4 Cir. 10/24/18), 257 So.3d 234, 236 (quoting State v. Vanburen, 2008-0824, pp. 4-5 (La. App. 4 Cir. 12/30/08), 3 So.3d 552, 555). “Whether a refusal to grant a continuance was justified depends on the circumstances of the particular case presented.” Id. (quoting State ex rel. B.M., 2000-2562, p. 4 (La. App. 4 Cir. 11/29/00), 774 So.2d 1042, 1045).

We find that the Defendant's delayed disclosure of Dr. Deland's expert report prejudices the State's ability to prepare for trial and rebut the insanity defense presented by Defendant. We thus find that the trial court's denial of the motion to continue was a clear abuse of discretion. Additionally, the trial judge indicated that he denied the motion to continue in order to “retain jurisdiction,” which is not a legal basis to deny a continuance. Accordingly, we grant the State's writ application and reverse the trial court's ruling denying the motion to continue.

WRIT GRANTED; JUDGMENT REVERSED

Judge Karen K. Herman

LOBRANO, J., CONCURS IN THE RESULT

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