SAVOY v. STATE THROUGH LOUISIANA DEPARTMENT OF HEALTH (2026)

In this matter involving public records requests, Defendant/Plaintiff-in-Reconvention, the State of Louisiana, through the Department of Health (“LDH”), appeals judgments that granted Plaintiff's/Defendant-in-Reconvention's, Sheila Savoy's, petition for injunctive relief and issued a mandatory injunction; denied LDH's motion to vacate that judgment; denied LDH's peremptory exceptions raising the objections of no cause of action and no right of action; and granted Ms. Savoy's claims for attorney's fees, statutory penalties, and costs. For the following reasons, we dismiss the appeal.

FACTS AND PROCEDURAL HISTORY

Ms. Savoy is a former employee of LDH whose employment was terminated. Ms. Savoy filed a civil service appeal of her termination and sought records from LDH to pursue her claims in that appeal.¹

Attorney J. Arthur Smith, III, representing Ms. Savoy, filed a request with the custodian of public records for LDH, pursuant to the Louisiana Public Records Law (“Public Records Law”), La. R.S. 44:1, et seq., on March 10, 2023.² That same day, LDH acknowledged receipt of the request (“March 10, 2023 request”). March 14, 2023, LDH notified Mr. Smith that it required specificity and clarification of the March 10, 2023 request and that some or all of the requested records potentially contained non-public material that would have to be separated from the public record prior to examination by Ms. Savoy and reproduction. After receiving no response, LDH closed out the request.

On April 6, 2023, Mr. Smith, on behalf of Ms. Savoy, filed another public records request with the custodian of public records for LDH. That same day, LDH acknowledged receipt of the request (“April 6, 2023 request”). On April 11, 2023, LDH emailed Mr. Smith notice that the April 6, 2023 request was being processed and that it would take an additional fifteen to thirty days for collection and review of the prospective records before they would be available for inspection or reproduction. LDH stated that “some or all of the prospective records may be exempt from disclosure, or that confidentiality and/or privilege issues may prevent the disclosure of the requested records” and that LDH would contact Mr. Smith immediately to state the legal basis for withholding any records responsive to his request. On April 19, 2023, LDH notified Mr. Smith that its fifteen-to-thirty-days estimate was not accurate as the “results of the email search alone yielded over 18,000 emails.” LDH sought further specificity and clarification of the April 6, 2023 request and again indicated that some or all of the requested records potentially contained non-public material that would have to be separated from the public record prior to Ms. Savoy's examination and reproduction. On May 16, 2023, LDH notified Mr. Smith that a “narrowed” email search yielded over 29,000 emails, more than the initial search. LDH again sought specificity and clarification of the April 6, 2023 request. After attempting to obtain narrowed search terms from Mr. Smith to refine the email results, LDH received no further communication from Mr. Smith. LDH then closed out the request.

On August 2, 2023, Mr. Smith, on behalf of Ms. Savoy, filed another public records request with the custodian of public records for LDH. That same day, LDH acknowledged receipt of the request (“August 2, 2023 request”). On August 14, 2023, LDH emailed Mr. Smith notice that the third request was being processed and that some of the requested records had “already been provided” to him in connection with the prior requests. LDH sought specificity and clarification of the August 2, 2023 request, as its preliminary email search “based on the parameters” that Mr. Smith provided had resulted in over 4,500 prospective responsive emails. On September 14, 2023, LDH notified Mr. Smith that it was still working to narrow the results as its search was “still returning approximately 5,000 individual emails.” LDH then remained in communication with Mr. Smith as it worked to refine the email results.

However, on September 15, 2023, Ms. Savoy filed a petition for injunctive relief pursuant to the Public Records Law against LDH and its employee, Mark J. Semien, an attorney supervisor with LDH's Bureau of Legal Services, who sent various emails in response to the requests through the LDH Records Center, powered by GovQA.³ Ms. Savoy alleged that Mr. Semien was the “custodian” of LDH's public records, and that after making requests for public records beginning on March 10, 2023, Defendants failed to comply with her requests and were in violation of the Public Records Law. Ms. Savoy prayed for:

(1) an order that Defendants promptly produce the records requested by Ms. Savoy or show cause why they should not be ordered to comply;

(2) a preliminary injunction requiring Defendants to immediately permit the inspection and to provide copies of the requested records to Ms. Savoy; enjoin Defendants from withholding the requested records from Ms. Savoy; and award Ms. Savoy reasonable attorney fees, costs, and statutory damages in the amount of $100.00 per day for each day of Defendants’ violations of the Public Records Law;

(3) a permanent injunction in the form and substance of the preliminary injunction; and

(4) that Defendants be cast for damages, attorney's fees, litigation expenses, and all costs of the proceedings.

Ms. Savoy also alleged that Mr. Semien was personally liable for her damages and was liable in solido with LDH for the payment of attorney's fees, litigation expenses, and costs in accordance with La. R.S. 44:35(E)(2).⁴

The trial court signed an order setting Ms. Savoy's requests for hearing on October 2, 2023.⁵

On September 22, 2023, LDH filed an answer and a reconventional demand for declaratory judgment. Additionally, Mr. Semien filed a peremptory exception raising the objection of no cause of action as to Ms. Savoy's claim against him. Mr. Semien argued that he was not the statutorily-defined “custodian” of public records for LDH; therefore, Ms. Savoy had no cause of action against him personally, in his capacity as a classified civil servant, nor as a staff attorney supervisor at LDH.

Ms. Savoy answered LDH's reconventional demand and opposed Mr. Semien's peremptory exception raising the objection of no cause of action. The record on appeal shows that the trial court never set LDH's reconventional demand for hearing. LDH prayed that its reconventional demand “be heard at the same time set for the hearing” on Ms. Savoy's requests for injunctive and other relief. The trial court signed an order on September 27, 2023, that set LDH's reconventional demand for hearing on “the 2nd day of October, 2023”. The hearing date was crossed through on that order. According to LDH, its reconventional demand remains “unresolved.”

Following the October 2, 2023 hearing, the trial court signed a judgment on October 17, 2023, which pertinently decreed:

This matter came on for hearing, of Plaintiff's Petition for Injunctive Relief Pursuant to the Public Records [Law] and Defendants’ Answer to Petition for Injunctive Relief Pursuant to the Public Records [Law], Peremptory Exception of No Cause of Action, and Reconventional Demand for Declaratory Judgment[6], on October 2, 2023.

***

After considering the pleadings, law, the argument of counsel, and the record, and for the oral reasons assigned by the Court on October 2, 2023:

IT IS ORDERED, ADJUDGED[,] AND DECREED that [P]laintiff's Petition for Injunctive Relief Pursuant to the Public Records [Law] be and it is hereby Granted;

IT IS FURTHER ORDERED, ADJUDGED[,] AND DECREED that [D]efendant shall make the approximately 4,600 emails comprising the records that are the subject of the Petition for Injunctive Relief Pursuant to the Public Records [Law], immediately available for viewing by [P]laintiff and that [D]efendant will have 45 days to produce, to [P]laintiff the emails [P]laintiff selects, from the approximately 4,600 emails;

IT IS FURTHER ORDERED, ADJUDGED[,] AND DECREED that a ruling on attorney's fees is deferred for 45 days or until the hearing, in this matter, scheduled for November 27, 2023.

On October 30, 2023, Defendants filed a motion for suspensive appeal of the trial court's October 17, 2023 judgment. In an order signed on November 8, 2023, the trial court denied Defendants’ motion for suspensive appeal. Defendants applied to this Court for supervisory review of that decision. This Court denied Defendants’ writ application as follows: “WRIT DENIED. The trial court's October 17, 2023 judgment is not a final and appealable judgment, as it does not resolve the [Plaintiff's demand for statutory penalties and is not designated as a final judgment. See La. [C.C.P.] arts. 1841, 1915.” Savoy v. State through Louisiana Dep't of Health, 2023-1256 (La. App. 1 Cir. 1/29/24), 2024 WL 323407, *1 (unpublished writ action).⁷

Thereafter, Defendants filed a motion to vacate the October 17, 2023 judgment; a peremptory exception raising the objection of no cause of action; and alternatively, a peremptory exception raising the objection of no right of action.⁸ As to Mr. Semien, Defendants argued that Ms. Savoy failed to state a cause of action that he is personally liable in solido with LDH, arguing that Mr. Semien is not the custodian of records for LDH but merely assisted the LDH custodian with the legal aspects of processing public records requests.

The trial court signed an order setting Defendants’ motion to vacate and exceptions of no cause and no right of action for hearing on July 31, 2024.

At the July 31, 2024 hearing, the trial court heard Defendants’ motion to vacate and exceptions of no cause and no right of action. The trial court also heard arguments and received evidence regarding Ms. Savoy's claims for statutory penalties, attorney's fees, and costs pursuant to the Public Records Law. LDH informed the trial court that Ms. Savoy's civil service case settled prior to the July 31, 2024 hearing. LDH further indicated that after several scheduling conflicts, Ms. Savoy visited LDH on three or four occasions and examined the 4,600 emails produced in accordance with the public records requests. At the conclusion of the hearing, the trial court denied LDH's motion to vacate the October 17, 2023 judgment and denied the exception of no cause of action and alternative exception of no right of action raised by LDH. The trial court sustained the exception of no cause of action raised by Mr. Semien.⁹ The trial court deferred its ruling on Ms. Savoy's claims for statutory penalties, attorney's fees, and costs under the Public Records Law. The trial court assigned those claims for hearing on August 28, 2024. There is no written judgment in the record memorializing the trial court's rulings made at the July 31, 2024 hearing.

Following the August 28, 2024 hearing, the trial court signed a judgment on November 7, 2024, which pertinently decreed:

This matter again came on for hearing on August 28, 2024 for a ruling on the [P]laintiff's claims for attorney's fees, statutory litigation expenses, penalties, and costs under the Louisiana Public Records [Law].

***

Considering the law and the evidence, and for oral reasons assigned[:]

IT IS ORDERED, ADJUDGE[D,] AND DECREED that the [P]laintiff, Sheila Savoy, be and is hereby awarded attorney[’]s fees and litigation expenses in the amount of Fourteen Thousand, Two Hundred and 00/100 Dollars ($14,200.00).

IT IS FURTHER[ ] ORDERED, ADJUDGED[,] AND DECREED that the Court awards statutory penalties under the Louisiana Public Records [Law] at the rate of $100 per day, exclusive of weekends and holidays, and calculated according to the accrual period from November 21, 2023, to July 31, 2024 for a total award of $17,500 in statutory penalties.

IT IS FURTHER[ ] ORDERED, ADJUDGED[,] AND DECREED that the above awarded sums shall bear legal interests from the date of the signing of this judgment until paid.

IT IS FURTHER[ ] ORDERED, ADJUDGED[,] AND DECREED that the [D]efendant, the State of Louisiana, through the Louisiana Department of Health, shall pay all costs of this proceeding.

LDH has appealed ¹⁰ the trial court's judgment signed on November 7, 2024. In this appeal, LDH has additionally assigned error to the judgment signed on October 17, 2023, and the oral rulings made at the July 31, 2024 hearing.¹¹

APPELLATE JURISDICTION

Appellate courts have the duty to examine subject matter jurisdiction sua sponte, even when the parties do not raise the issue. Bayou Manchac Holdings, LLC v. Iberville Parish Council, 2023-0446 (La. App. 1 Cir. 12/14/23), 380 So.3d 635, 638. This Court's appellate jurisdiction extends to final judgments, which are those that determine the merits in whole or in part, and to interlocutory judgments when expressly provided by law. See La. C.C.P. arts. 1841 and 2083; Jones v. Fogg, 2024-1048 (La. App. 1 Cir. 5/30/25), 413 So.3d 580, 583, writ denied, 2025-01069 (La. 11/19/25), 420 So.3d 1186; Prepotente v. Williams, 2024-0906 (La. App. 1 Cir. 2/21/25), 406 So.3d 641, 643.

Here, LDH appeals the trial court's judgment signed on November 7, 2024. In addition, LDH has assigned error to the judgment signed on October 17, 2023, and to the oral rulings made at the July 31, 2024 hearing. When an unrestricted appeal is taken from a final judgment, the appellant is entitled to seek review of all adverse interlocutory judgments prejudicial to him, in addition to the review of the final judgment. Judson v. Davis, 2004-1699 (La. App. 1 Cir. 6/29/05), 916 So.2d 1106, 1112, writ denied, 2005-1998 (La. 2/10/06), 924 So.2d 167. Thus, if we determine that the November 7, 2024 judgment is final, LDH is entitled to also seek review of the October 17, 2023 judgment and the July 31, 2024 oral rulings.

There is no dispute that the trial court has never set for hearing, nor ruled on, LDH's reconventional demand, originally filed on September 22, 2023. The November 7, 2024 judgment LDH appeals does not determine the merits of LDH's reconventional demand. Because LDH's reconventional demand is pending, the November 7, 2024 judgment only partially determines the merits of this action and is only appealable if authorized by La. C.C.P. art. 1915.¹² See Tanner v. Morgan, 2024-0974 (La. App. 1 Cir. 2/26/25), 407 So.3d 74, 77.

The November 7, 2024 judgment does not fall within any of the categories of partial judgments subject to immediate appeal listed in La. C.C.P. art. 1915(A). Therefore, the appeal of the November 7, 2024 judgment is governed by Subsection B of that article, which provides that a partial judgment “shall not constitute a final judgment unless it is designated as a final judgment by the court after an express determination that there is no just reason for delay.” La. C.C.P. art. 1915(B)(1). The trial court did not designate the November 7, 2024 judgment as final for purposes of immediate appeal or determine that there was no just reason for delay. Therefore, the November 7, 2024 judgment is not subject to an immediate appeal. See La. C.C.P. art. 1915(B)(2). Consequently, this court lacks appellate jurisdiction to review the November 7, 2024 judgment. See La. C.C.P. arts. 1841, 1911, and 2083. See also Louisiana Workers’ Compensation Corp. v. Sims, 2014-1378 (La. App. 1 Cir. 4/24/15), 2015 WL 1882608, *3 (unpublished).

The proper procedural vehicle to contest an interlocutory judgment is by application for supervisory writs filed within thirty days of rendition of the interlocutory judgment. See La. C.C.P. art. 2201; Johnson v. C's Transportation Services, LLC, 2020-0338 (La. App. 1 Cir. 8/4/21), 2021 WL 3418693, *1 (unpublished). We recognize that this Court has discretionary authority to convert an appeal from an interlocutory judgment to an application for supervisory writs. Succession of Overton, 2024-0119 (La. App. 1 Cir. 10/17/25), 423 So.3d 1114, 1121. The appellate courts of this state ordinarily convert an appeal to an application for supervisory writs only if the motion for appeal is filed within the thirty-day time period allowed for the filing of an application for supervisory writs under Rule 4-3 of the Uniform Rules—Courts of Appeal, and where a determination as to the reviewable issues before us may facilitate resolution of the remaining litigation and foster judicial economy. See Matter of Succession of Porche, 2016-0538 (La. App. 1 Cir. 2/17/17), 213 So.3d 401, 406 n.2; Succession of Overton, 423 So.3d at 1121.

In the instant case, LDH filed its motion for suspensive appeal on December 9, 2024, within the thirty-day period for timely filing an application for supervisory writs after the signing of the November 7, 2024 interlocutory judgment.¹³ However, converting LDH's appeal of the November 7, 2024 interlocutory judgment to an application for supervisory writs to allow us to review the November 7, 2024 interlocutory judgment under our supervisory jurisdiction will not facilitate a resolution of the litigation nor foster judicial economy. See Succession of Overton, 423 So.3d at 1121.

First, if we review the November 7, 2024 interlocutory judgment under our supervisory jurisdiction, LDH would not be entitled to also seek review of the October 17, 2023 judgment ¹⁴ , nor the oral rulings made at the July 31, 2024 hearing.¹⁵ An appellate court may consider interlocutory judgments as part of an unrestricted appeal from a final judgment. Henry v. Sullivan, 2016-0564 (La. App. 1 Cir. 7/12/17), 223 So.3d 1263, 1272. See also Judson, 916 So.2d at 1112. The November 7, 2024 judgment is not a final judgment; therefore, LDH would not be entitled to review of the October 17, 2023 judgment, nor of the oral rulings made at the July 31, 2024 hearing, were this Court to review the November 7, 2024 judgment under our supervisory jurisdiction. Alternatively stated, an appellant may not seek review of other interlocutory judgments in connection with an interlocutory judgment on review under this Court's supervisory jurisdiction.

Second, once a final judgment is rendered in this matter, LDH will be entitled to seek review of all adverse interlocutory judgments prejudicial to it, in addition to the review of the final judgment. See Judson, 916 So.2d at 1112. Until such time, to review the November 7, 2024 interlocutory judgment that awarded attorney's fees, penalties, and costs pursuant to the earlier rulings (i.e., the October 17, 2023 judgment and the oral rulings made at the July 31, 2024 hearing) under our supervisory jurisdiction would promote judicial inefficiency and piecemeal litigation. See R.J. Messinger, Inc. v. Rosenblum, 2004-1664 (La. 3/2/05), 894 So.2d 1113, 1122.

Finally, we conclude that the factors enumerated in Herlitz Construction Co., Inc. v. Hotel Investors of New Iberia, Inc., 396 So.2d 878 (La. 1981) (per curiam) limit our discretionary authority to consider this matter as a supervisory writ application. For example, if we were to find that the trial court's rulings contained in the November 7, 2024 judgment were arguably incorrect, correcting those rulings now would not dispose of the entirety of the case, making immediate review inefficient and a waste of judicial resources. See Herlitz, 396 So.2d at 878. Appellate relief may be available once a final judgment has been rendered. See La. C.C.P. art. 2083; Prepotente, 406 So.3d at 644.

DECREE

We dismiss the appeal—filed by the State of Louisiana, through the Department of Health—of the trial court's judgment signed on November 7, 2024. We assess all costs of the appeal in the amount of $1,540.00 to the State of Louisiana, through the Department of Health.

APPEAL DISMISSED.

FOOTNOTES

1.   Ms. Savoy has since settled and dismissed her civil service appeal.

2.   “This Chapter shall be known and may be cited as the ‘Public Records Law.’ ” La. R.S. 44:1.1.

3.   GovQA is the software portal used by LDH to process public records requests.

4.   Prior to its amendment by 2024 La. Acts No. 493 § 1 (eff. June 5, 2024), La. R.S. 44:35(E)(2) pertinently provided that “[t]he custodian shall be personally liable for the payment of damages ․ and shall be liable in solido with the public body for the payment of the requestor's attorney fees and other costs of litigation[.]” The former version of La. R.S. 44:35(E)(2) is applicable in the instant matter.

5.   The trial court ordered Defendants to show cause “why a preliminary injunction should not issue herein ordering the Defendants to promptly provide the records requested by the Plaintiff, why they should not be cast in judgment for statutory damages in the amount of $100.00 per day for each day of their alleged violation of the [Public Records Law], and why they should not be cast for the Plaintiff's reasonable attorney[’]s fees and litigation expenses, and for all costs of this proceeding.”

6.   Although the October 17, 2023 judgment notates that LDH's reconventional demand for declaratory judgment was before the trial court at the October 2, 2023 hearing, as discussed supra, the trial court never set LDH's reconventional demand for hearing, and further, the reconventional demand was not argued by the parties nor ruled on by the trial court at the October 2, 2023 hearing.

7.   We note this Court is not bound by a writ panel's previous decision issued in another matter, regardless of whether that decision is published or not. A regular appeal panel has the authority, and indeed the duty, to review, overrule, modify, and/or amend a writ panel's decision on an issue when, after reconsidering the issue to the extent necessary to determine whether the writ panel's decision was correct, the appeal panel finds that the writ panel's decision was in error. Mere doubt as to the correctness of the prior ruling by a writ panel is not enough to change the prior ruling; only where it is manifestly erroneous, or where application of the law of the case doctrine would result in an obvious injustice, should we overrule or modify the prior ruling. Elee v. White, 2019-1633 (La. App. 1 Cir. 7/24/20), 393 So.3d 896, 900, writ denied, 2020-01048 (La. 11/10/20), 303 So.3d 1038.

8.   For ease of reference, we refer to the peremptory exception raising the objections of no cause of action and no right of action as an “exception of no cause of action” and “exception of no right of action.”

9.   At the time LDH lodged the record in the instant appeal, the record on appeal contained no written ruling or judgment sustaining Mr. Semien's exception of no cause of action and dismissing Ms. Savoy's claims against him.

10.   LDH filed a motion for suspensive appeal on December 9, 2024. The trial court signed an order of appeal on January 9, 2025, notice of which was transmitted by the Clerk of Court to the parties on January 16, 2025.

11.   After the appeal was lodged, this Court issued an interim order directing the Clerk of Court for the Nineteenth Judicial District Court (“19th JDC”) to supplement the record on appeal with the transcript of the October 2, 2023 hearing; the transcript of the July 31, 2024 hearing; and the judgment (if any was reduced to writing) of any oral rulings made at the July 31, 2024 hearing. On August 21, 2025, the 19th JDC Clerk supplemented the record on appeal with the minute entry for the July 31, 2024 hearing; the minute entry for the August 28, 2024 hearing; the November 7, 2024 judgment; the transcript of the October 2, 2023 hearing; and the transcript of the July 31, 2024 hearing. However, the record was not supplemented with any judgment reducing the trial court's July 31, 2024 oral rulings to writing.

12.   Louisiana Code of Civil Procedure article 1915 was recently amended and reenacted by 2025 La. Acts No. 250, § 3 (eff. Aug. 1, 2025), largely to restore the Article to its pre-1997 form. See La. C.C.P. art. 1915, Comments—2025, Comments (a) and (b). The revisions remove from Paragraph B the authority of the trial court to designate a judgment as final and appealable after an express determination that there is no just reason for delay. As a result, Paragraph A now provides a list of judgments from which an appeal may be taken. This change seeks to remove uncertainty as to whether an appeal or a supervisory writ should be taken from a judgment that does not grant the successful party or parties all of the relief prayed for or may not adjudicate all of the issues in the case. La. C.C.P. art. 1915, Comments—2025, Comment (a). Paragraph B retains much of the language of former Paragraph C. The language of Paragraph C is new and provides for interlocutory judgments that are not appealable. See La. C.C.P. art. 2083(C); Comments—2025, Comment (b) to La. C.C.P. art. 1915. These amendments have prospective application only and shall not apply to appeals and supervisory writs filed prior to August 1, 2025, the effective date of the Act. See 2025 La. Acts No. 250, § 6 (eff. Aug. 1, 2025). The instant appeal was filed prior to the effective date of the 2025 amendment. Thus, we will apply the prior version of La. C.C.P. art. 1915.

13.   Thirty days from November 7, 2024 was Saturday, December 7, 2024, which was a legal holiday in the State of Louisiana. See La. R.S. 1:55. Therefore, the thirty-day period ran until December 9, 2024, the following Monday. See La. C.C.P. art. 5059.

14.   This Court previously ruled that the October 17, 2023 judgment is not a final, appealable judgment; therefore, it is an interlocutory judgment. See Savoy, 2024 WL 323407 at *1.

15.   The oral rulings made at the July 31, 2024 hearing and challenged by LDH are: (1) the denial of LDH's motion to vacate the October 17, 2023 judgment; (2) the denial of LDH's exception of no cause of action; and (3) the denial of LDH's alternative exception of no right of action. The record on appeal does not contain any judgment or written ruling memorializing the trial court's July 31, 2024 rulings that are challenged by LDH.Assuming those rulings were interlocutory in nature, the proper procedural vehicle to contest an interlocutory judgment is an application for supervisory writs. La. C.C.P. art. 2201; Prepotente, 406 So.3d at 643; Jones, 413 So.3d at 583. A supervisory writ application challenging a trial court's interlocutory judgment must be filed within thirty days of the notice of judgment. See Rule 4-2 and Rule 4-3 of the Uniform Rules—Courts of Appeal; Prepotente, 406 So.3d at 643; Jones, 413 So.3d at 583. When an interlocutory judgment is rendered in open court, its rendition constitutes notice to all parties, unless certain exceptions apply. La. C.C.P. art. 1914(A); Prepotente, 406 So.3d at 643; Jones, 413 So.3d at 583. Those exceptions are: if the trial court orders that an interlocutory judgment be reduced to writing; if the trial court takes the interlocutory matter under advisement; or if a party requests that the interlocutory judgment be reduced to writing within ten days of its rendition in open court. La. C.C.P. art. 1914(B) (prior version applies here; prior to its amendment by 2025 La. Acts No. 250 § 3 (eff. Aug. 1, 2025)); Prepotente, 406 So.3d at 643; Jones, 413 So.3d at 583-84. In such cases, the interlocutory judgment shall be reduced to writing, the trial court clerk shall mail notice of the written judgment to each party, and the thirty-day delay for filing a writ application begins from the date of the mailing of the notice. See La. C.C.P. art. 1914(B) (prior version applies here; prior to its amendment by 2025 La. Acts No. 250 § 3 (eff. Aug. 1, 2025)); Rule 4-2 and Rule 4-3 of the Uniform Rules—Courts of Appeal; Prepotente, 406 So.3d at 643-44.In this case, the trial court rendered its interlocutory rulings in open court on July 31, 2024. After ruling, the trial court ordered Mr. Smith (counsel for Ms. Savoy) to prepare a judgment, circulate it to all counsel, and present it to the trial court for signature. Therefore, one of the exceptions to La. C.C.P. art. 1914(B) applied (prior version applies here; prior to its amendment by 2025 La. Acts No. 250 § 3 (eff. Aug. 1, 2025)).As discussed in Footnote 11 supra, this Court ordered the 19th JDC Clerk to supplement the record with a judgment (if any was reduced to writing) of any oral rulings made by the trial court at the July 31, 2024 hearing. We received no judgment or written ruling memorializing those rulings from the 19th JDC Clerk with the August 21, 2025 record supplement. Therefore, even if the July 31, 2024 rulings were later reduced to writing, notice began from the rendition of the interlocutory judgments made in open court. Prepotente, 406 So.3d at 644 n.1; Jones, 413 So.3d at 584; Spangler v. Chiasson, 95-2113 (La. App. 1 Cir. 4/22/96), 681 So.2d 956, 957 (per curiam). Furthermore, even if the July 31, 2024 rulings are reduced to writing at some point in the future, supervisory review of such a judgment would still not be considered a timely-filed writ application. See Prepotente, 406 So.3d at 644 n. 1; Jones, 413 So.3d at 584. Accordingly, LDH failed to timely seek supervisory review of the July 31, 2024 oral rulings. Because the July 31, 2024 oral rulings were not timely challenged, we have no authority to review them now under our supervisory jurisdiction.To the extent the July 31, 2024 oral rulings are not considered interlocutory, there can be no appeal of an oral ruling. See Bridges v. Bridges, 2017-1178 (La. App. 1 Cir. 12/7/17), 2017 WL 6055425, *1 (unpublished). A final, appealable judgment must be reduced to writing. La. C.C.P. art. 1911; Rogers v. Rogers, 2018-0239 (La. App. 1 Cir. 9/21/18), 2018 WL 4523930, *2 (unpublished); Hains v. Hains, 2009-1337 (La. App. 1 Cir. 3/10/10), 36 So.3d 289, 301 (an oral ruling must be reduced to writing to be considered a final judgment).

EDWARDS, J.