The Louisiana Supreme Court reversed a decision Monday that had recused 16th Judicial District Judge Keith Comeaux from the case of a former St. Martin Parish Sheriff’s deputy who had been convicted of killing her husband in 2013.
In its decision, the court said that Comeaux should not have been recused, reinstating him as the trial judge hearing the case of Chrystal Clues-Alexander.
Clues-Alexander had pleaded guilty to the shooting death of her husband, Kendall Alexander. While awaiting the sentencing phase of the trial, 16th JDC Judge Lori Landry ruled in favor of a motion to recuse Comeaux last summer based on his issuing, then rescinding, a restraining order against Kendall Alexander in 2005.
“We find it noteworthy the motion to recuse was filed after Judge Comeaux had already accepted the defendant’s guilty plea, albeit before sentencing,” the court wrote in reversing the order. “Further, we do not find the potential for bias for the average judge in this position is unconstitutionally high.”
It was only a few months later that Landry was herself the subject of hundreds of recusal motions from the 16th JDC District Attorney’s Office, claiming that she was prejudiced against the office’s prosecutors in criminal cases. Those motions were dropped after a hearing in December.
“Even if the dismissal of the protective order was legally incorrect, and we are not expressing such an opinion, it would still only be classified as an adverse ruling performed within a judge’s authority,” the court said. “Adverse rulings, alone, do not show bias or prejudice requiring recusal.”
In a concurring opinion, Associate Justice Scott J. Crichton said that if the court allowed the ruling to stand, attorneys could use a judge’s previous actions, no matter how inconsequential, to choose which judges they wanted to hear their cases.
“If allowed to stand, the lower courts’ rulings could be viewed as precedent for a party to criticize past judicial orders in a concerted effort to force a recusal, thereby effectively engaging in the distasteful exercise of judge shopping,” Crichton said.
Prior to Kendall Alexander’s death, he and Clues-Alexander had a volatile relationship with multiple reports of domestic abuse.
In August 2014, she was arraigned in his shooting death. The case was set for trial and continued multiple times before being assigned to Comeaux in 2018, according to court filings.
Comeaux was randomly assigned to Clues-Alexander’s case. She pleaded guilty to a reduced charge of manslaughter in April 2018. Clues-Alexander, who has remained free on bond while awaiting sentencing, faces up to 40 years in prison.