John T. Fuller v. State of Louisiana; Jeff Landry in His Official Capacity as Governor; Elizabeth B. Murrill, in Her Official Capacity as Attorney General; Nancy Landry, in Her Official Capacity as Secretary of State; And Chelsey Richard Napoleon, in Her Official Capacity as Clerk of Court for the Parish of Orleans

FOR IMMEDIATE NEWS RELEASE NEWS RELEASE #037 FROM: CLERK OF SUPREME COURT OF LOUISIANA The Opinions handed down on the 31st day of July, 2026 are as follows: PER CURIAM: 2026-CD-00927 JOHN T. FULLER VS. STATE OF LOUISIANA; JEFF LANDRY IN HIS OFFICIAL CAPACITY AS GOVERNOR; ELIZABETH B. MURRILL, IN HER OFFICIAL CAPACITY AS ATTORNEY GENERAL; NANCY LANDRY, IN HER OFFICIAL CAPACITY AS SECRETARY OF STATE; AND CHELSEY RICHARD NAPOLEON, IN HER OFFICIAL CAPACITY AS CLERK OF COURT FOR THE PARISH OF ORLEANS (Parish of East Baton Rouge) STAY LIFTED. INJUNCTION LIFTED. REVERSED AND RENDERED. SEE PER CURIAM. Weimer, C.J., dissents and assigns reasons. McCallum, J., additionally concurs and assigns reasons. Griffin, J., dissents and assigns reasons. Guidry, J., dissents and assigns reasons. Cole, J., additionally concurs and assigns reasons. Burris, J., additionally concurs and assigns reasons. 1  SUPREME COURT OF LOUISIANA No. 2026-CD-00927 JOHN T. FULLER VS. STATE OF LOUISIANA; JEFF LANDRY IN HIS OFFICIAL CAPACITY AS GOVERNOR; ELIZABETH B. MURRILL, IN HER OFFICIAL CAPACITY AS ATTORNEY GENERAL; NANCY LANDRY, IN HER OFFICIAL CAPACITY AS SECRETARY OF STATE; AND CHELSEY RICHARD NAPOLEON, IN HER OFFICIAL CAPACITY AS CLERK OF COURT FOR THE PARISH OF ORLEANS On Supervisory Writ to the 19th Judicial District Court, Parish of East Baton Rouge PER CURIAM This matter presents the question of whether Act 748 of the 2026 Regular Session (“Act 748”) was constitutionally enacted. For the following reasons, we conclude the legislature validly enacted Act 748, reverse the trial court’s judgment declaring the Act unconstitutional, and vacate the preliminary injunction against it. BACKGROUND Orleans Parish has long maintained a unique judicial structure among all parishes in the state, as it has separate civil and criminal courts. The framers of the 1974 Constitution preserved that distinct structure in La. Const. Art. V, § 32, while making the enumerated Orleans Parish courts and offices “subject to change by law,” notwithstanding any contrary constitutional provision. Id. Section 32 reflected cognizance of the fact that the courts of Orleans Parish were conceived in a different era, when New Orleans was much larger than any other place in the state. A useful historical perspective is gained by contemplating the shift away from Orleans Parish, even within its own region. That change was in its infancy at the time of the constitutional convention but accelerated rapidly in the years 1 following adoption of the 1974 Constitution. In 1960, the population of New Orleans reached its peak of more than 600,000 residents. In the decades that followed, the population of the city itself declined as surrounding parishes experienced substantial growth. The New Orleans metropolitan statistical area, together with part of the Northshore, comprises nearly 1.3 million people, while the 2025 census estimate places the current population of Orleans Parish at 362,154. There were times in history when Orleans Parish approached a quarter of the state’s population, now it comprises barely a quarter of the New Orleans region. During the legislative debate over Act 748, state leadership expressed a desire to address the disparity between the state funding spent on the judiciary in Orleans Parish compared to the rest of Louisiana. The opening address called for reform by highlighting that more than double was spent by the state in Orleans Parish compared to East Baton Rouge Parish, the state’s most populous parish with its busiest court. Act 748 of the 2026 Regular Session, signed on June 3, 2026, made changes to the Orleans Parish courts. Among other changes, the Act abolishes three judgeships on the criminal district court by abolishing Sections A, E, and J at the conclusion of the incumbents’ terms. The Act further provides that no further elections will be held for those abolished judgeships. See La. R.S. 13:1335(A)-(B). Even after implementation of Act 748, Orleans Parish retains the most judges in the state, including more than those judicial districts with more cases and larger populations.1 Act 748 reduced the number of general trial judges in Orleans Parish from 27 to 24, still 50% more judges than in Jefferson Parish, its larger neighbor.2 1 The Legislature’s consideration of Act 748 occurred against a backdrop of fiscal and administrative concerns. Publicly reported caseload statistics provide administrative context. The Louisiana Supreme Court’s 2025 Annual Report reflects that the Nineteenth Judicial District Court in East Baton Rouge Parish, with only 15 judges, reported more than double the combined filings of the Orleans Parish courts. See 2025 La. Sup. Ct. Annual Report, p.47, available at https://www.lasc.org/press_room/annual_reports/reports/2025_ Annual_Report.pdf. 2 Orleans Parish retains 14 trial judges in civil district court and ten judges in criminal district court, which is comprised of nine judges and one elected magistrate judge. There are additionally four appointed commissioners in the criminal district court that are not counted in this total. 2  Plaintiff, Judge John Fuller, was elected to Section J on May 16, 2026, and retains that seat through the expiration of the term on December 31, 2026. Had Act 748 not abolished Section J at the end of his term, Judge Fuller intended to run again. On June 29, 2026, Judge Fuller filed this lawsuit seeking a declaratory judgment, preliminary and permanent injunctive relief, and, alternatively, a writ of mandamus. Judge Fuller’s principal contention was that Act 748 required the approval of two-thirds of the elected members of each house under La. Const. Art. V, § 15(D), which is applicable to district courts generally, and he argues that it should also govern here. He also argued that La. Const. Art. V, § 32 applied to those courts and offices named in it, like the clerk of court, but did not apply to the judges of those named courts. Judge Fuller asserted that change may be enacted under Section 32 for the criminal district court as a whole or as an entity, but that it does not authorize change to individual judgeships by ordinary legislation. Because the conference committee report received 25 votes in the 39-member Senate and 62 votes in the 105-member House, Judge Fuller alleged that Act 748 did not pass by the constitutionally required margin. In the alternative, his petition asserted claims based on the right to vote, equal protection, and the constitutional prohibition against local or special laws. He requested relief preserving the abolished sections for the August 2026 qualifying period and the November 2026 election. The state filed an opposition to the requested injunction, a dilatory exception of unauthorized use of summary proceeding, and peremptory exceptions of no cause of action and no right of action. In short, the State argued that Act 748 was a valid exercise of the Legislature’s authority under Article V, § 32, and that Judge Fuller’s requests were procedurally barred. Effective January 1, 2027, Orleans Parish also retains 12 judges serving on its courts of limited jurisdiction: three in Juvenile Court following abolition of Section F, five in Municipal and Traffic Court following the abolition of Divisions B and F; and four judges in the First and Second City Court, who were unaffected. An additional juvenile judgeship and municipal judgeship are designated for recission at their next vacancy. La. R.S. 13:1595(B) and 13:2492 (A)(8). 3  Following a hearing on July 14, 2026, the trial court signed a judgment granting a preliminary injunction in Judge Fuller’s favor. The court declared Act 748 “null and void,” concluding that La. Const. Art. V, § 32 did not apply to the abolition of the criminal district court sections and the Act had not received the supermajority vote required by La. Const. Art. V, § 15(D). The court refused to hear the State’s exceptions. The judgment directed the Orleans Clerk of Court to receive and preserve provisionally any qualifying papers tendered for the abolished judgeships and prohibited the Secretary of State from taking final or irrevocable action omitting those offices from the November ballot. The State sought a suspensive appeal pursuant to La. R.S. 13:4431 and requested that the injunction be suspended in all respects during that appeal. No order granting the appeal had been signed when Judge Fuller filed an emergency writ application directly in this Court, requesting that we assume plenary supervisory jurisdiction and that we resolve the constitutional question before the period for qualifying opens. Given the compressed timeline due to the upcoming election qualifying dates and the statewide importance of the constitutional question, this Court assumed supervisory jurisdiction and stayed the proceedings below. John T. Fuller v. State of Louisiana, et al., 26-0927 (La. 7/17/26), --- So. 3d --- (2026 WL 2105672). DISCUSSION In the interests of judicial economy and to provide a definitive resolution before the opening of the election qualifying period, we exercise our plenary supervisory authority under La. Const. Art. V, § 5(a). The “[s]upervisory authority of this court is plenary, unfettered by jurisdictional requirements, and exercisable at the complete discretion of the court,” regardless of whether lower courts have acted. Marionneaux v. Hines, 05-1191, p. 4 (La. 5/12/05), 902 So. 2d 373, 376. Pursuant to that authority, we decide the underlying constitutional question notwithstanding 4 certain procedural errors committed by the trial court, discussed further herein. Review of a judgment determining the constitutionality of a statute presents a question of law to be reviewed de novo. See Fisher v. Harter, 24-0359, p. 5 (La. 10/25/24), 395 So. 3d 806, 811. Statutes are presumed constitutional, and the party challenging the statute has the burden of proving its unconstitutionality. Id.3 Importantly, the parties agree the trial court’s order was overbroad insofar as it declared all of Act 748 “null and void.” Judge Fuller challenged only the provisions related to criminal district court judgeships, specifically Act 748’s abolition of Sections A, E, and J, its bar on qualifying and the implementation of its provisions, and its application to the November 3, 2026, elections for those sections. See La. R.S. 13:1335(A)-(B), 13:1343(A), 13:1383. I. Act 748 Was Validly Enacted and La. Const. Article V, § 32 Is Controlling The Court’s role in construing a constitutional provision is to determine and give effect to the intent of the people of Louisiana who adopted it. Radiofone, Inc. v. City of New Orleans, 630 So. 2d 694, 698 (La. 1994). When the constitutional text is clear and its application does not produce absurd consequences, it must be applied strictly as written. Id. Two provisions of Article V of the Louisiana Constitution are relevant to this case. Section 15(D) provides: (D) Number of Judges. The legislature may change the number of judges in any judicial district by law enacted by two-thirds of the elected members of each house. However, Section 32, the provision particular to Orleans Parish, provides: Except for provisions relating to terms of office as provided elsewhere in this Article, and notwithstanding any other contrary provision of this constitution, the following courts and officers in Orleans Parish are continued, subject to change by law; the civil and criminal district courts; the city, municipal, traffic, and juvenile courts; the clerks of the civil and criminal district courts; the civil and criminal sheriffs; the 3 Because we have exercised plenary jurisdiction over the constitutionality of the Act, a discussion of defendants’ remaining exceptions is pretermitted. 5  constables and the clerks of the first and second city courts; the register of conveyances; and the recorder of mortgages. (Emphasis added.) The phrase “notwithstanding any provision of law to the contrary” is a well- established term signaling that the statute or provision containing the phrase takes precedence. Antonin Scalia and Bryan A. Garner, Reading Law: The Interpretation of Legal Texts, § 13 (2012). The Supreme Court of the United States has also recognized the principle that “the use of such a ‘notwithstanding’ clause clearly signals the drafter’s intention that the provisions of the ‘notwithstanding’ section override conflicting provisions of any other section.” Cisneros v. Alpine Ridge Group, 508 U.S. 10, 18 (1993). In Davenport v. Hardy, 349 So.2d 858 (La. 1977), when interpreting Section 32 of the Louisiana Constitution, this Court held that “the Constitution generally establishes the Legislature’s power to govern [office(s) under § 32]. It imposes no limitations or restrictions on the exercise of that power[.]” Id. at 863 (emphasis supplied). The courts and officers enumerated in Section 32 were placed under the legislature’s plenary authority and made “subject to change by law,” meaning “the normal legislative majority vote,” notwithstanding other constitutional provisions. Crockett v. State, 26-0594, pp.3-5 (La. 6/1/26), --- So. 3d --- (2026 WL 1599484). Judge Fuller accepts the holding of Crockett, that Section 32 authorizes the legislature to make changes concerning the listed officers and even the listed courts. He contends, however, that Section 15 still governs any change to the number of judges and thus that issue requires a supermajority vote. That argument is unavailing. Orleans Parish has long maintained a unique court structure. Id. As part of the compromises leading to the 1974 Constitution, the Convention continued this “anomalous structure with numerous extra offices and judges compared to the rest of the state” but “affirmatively rejected attempts to protect them into the future.” Id. 6  A plain reading of La. Const. Art. V, § 32 establishes the constitutionality of Act 748. The “civil and criminal district courts” of Orleans Parish are expressly governed by Section 32 and made “subject to change by law.” Id. See also State v. Francois, 445 So. 2d 416, 418 (La. 1983) (reiterating the legislature’s “plenary power” over the Orleans Parish courts which “the legislature may completely abolish, partially erase or otherwise change”). Section 32 identifies only one exception to that authority which we identified as La. Const. Art. V, § 21 and it is not implicated here. Id. Judge Fuller contends the two provisions can be harmonized because Section 32 authorizes the legislature to change the Orleans Parish courts, but not their judges.4 He describes this as “who” can make the change as opposed to “how” the change must be made. That distinction is unpersuasive. By making the Orleans Parish civil and criminal district courts “subject to change by law,” Section 32 prescribes ordinary legislation as the mechanism for making those changes. The supermajority requirement in Section 15(D) therefore conflicts, and must yield to, the regular majority vote mechanism applicable under Section 32. That conflict is clearly resolved by the “notwithstanding” clause of Section 32. “[T]he catchall notwithstanding is a failsafe way of ensuring that the clause it introduces will absolutely, positively prevail.” Scalia & Garner, Reading Law, § 13 at 127. The authority over the “courts” granted to the legislature in Section 32 cannot be severed from its authority over the judges who constitute those courts. This Court has recognized that Section 32 permits the Legislature to “completely abolish” statutory provisions concerning this court. Francois, 445 So. 2d at 418. Judge Fuller’s interpretation would produce the incongruous result that the legislature 4 Paragraph B of La. Const. Art. V, § 15 applies to other district courts by continuing then-existing courts and providing parameters governing their merger. Even Judge Fuller’s brief agrees this paragraph would not apply to restrict a court merger in Orleans Parish. But that exposes an obvious inconsistency in his argument: why should one paragraph of Section 15 apply to restrict the legislature if, as we all agree, the other does not? 7 could abolish the court by ordinary legislation, impacting all judges, yet cannot reduce that court by three judgeships without a two-thirds vote. The text of Section 32 is clear and that answers this inquiry. Nevertheless, Judge Fuller points to certain records of debate from the constitutional convention to support his argument. He correctly observes that the convention debate centered on merging the civil and criminal district courts. But it is incorrect to divine from that debate a principle that places New Orleans under the same provisions as other courts for every purpose except mergers.5 That is not what our Constitution says, and therefore not what it does. The dissenting justices also rely on philosophical platitudes and a law review article while totally ignoring the salient provision of the Constitution specifically directed at the legislative power concerning the Orleans Parish judiciary. If the legislative authority under Section 32 can only be used pursuant to the other provisions of the Constitution, then there is no reason for the “notwithstanding” clause. It would be totally superfluous. The reality glossed over by the dissents, presumably because there is no answer other than the obvious one, is that the legislative authority under that Section existing “notwithstanding any other contrary provision of this constitution” means exactly that. This Court has long recognized that convention debates “cannot be resorted to for the purpose of varying the otherwise clear and unambiguous meaning of a constitutional provision.” Succession of Lauga, 624 So. 2d 1156, 1165 (La. 1993). In any event, the final actions taken by the delegates through their votes speak louder than the reasons debated. Here, the delegates voted to delete from the draft of Section 32 a proposed provision imposing a two-thirds supermajority requirement on the legislature’s authority under that Section. Id. The dissenting justices and Judge 5 It is similarly wrong to assume that because certain examples related to courts of limited jurisdiction that the provision only applies to those courts when all Orleans Parish courts are listed. 8 Fuller would have us ignore the clear text of the Constitution to impose a restriction on the legislature that the delegates expressly voted on and rejected. The text of our Constitution continued the Orleans Parish civil and criminal district courts “subject to change by law,” made that legislative authority controlling “notwithstanding any other contrary provision of this constitution.” That was what was placed before the people of Louisiana and adopted by them; therefore, the people of Louisiana exclusively vested the decisions concerning these courts to the legislative majority they elect to represent them. II. Act 748 Is Not a Local Law and Is Valid Under Plaintiff’s Under Theories The petition also asserted claims based on the right to vote, equal protection, and the constitutional restrictions concerning the passage of local or special laws. Those claims are not emphasized before this Court, and, in any event, provide no alternative basis for sustaining the preliminary injunction. As to the local law claim under La. Const. Art. III, § 13, this Court has already recognized the “longstanding view that all laws concerning the state’s courts and judicial officers such as clerks, even if limited in scope, are matters of statewide importance and general concern. They are not local laws regardless of geographic remit.” Crockett, 26-0594, p. 4 n.1, --- So.3d at ---. The three dissenting justices attacked that widely understood principle with one justice even stating it lacked any supporting authority. Their conclusion would have dangerous and far-reaching consequences, likely invalidating many hundreds of laws concerning the operation of every trial court in Louisiana.6 This illustrates the instability that results when courts fail to follow well settled law to advance erroneous arguments arising from an otherwise sympathetic cause or sensitive case. 6 A substantial portion of Title 13 of the Louisiana Revised Statutes of 1950, as amended, is customized to particular courts but was adopted without local advertisement. 9  In any event, that approach was not merely dangerous, it was also wrong. Our jurisprudence constante has held for over 140 years that a statute is not local or special merely because its immediate operation is geographically limited when it concerns a subject “in which the people at large are interested.” Polk v. Edwards, 626 So. 2d 1128, 1133-35 (La. 1993) (explaining that a law is not “a local law because it can only operate in a particular locality . . . if the legislation is general rather than local or special, neither the prohibitions regarding the enumerated subjects nor the requirement for local advertisement apply”). The Polk Court noted that this principle was “long recognized,” citing inter alia, State v. Dalon, 35 La. Ann. 1141, 1143-44 (La. 1883) and State ex rel. Grosch v. New Orleans, 211 La. 241, 29 So.2d 778 (La. 1947).7 In Dalon, there was a challenge to the Act creating the Orleans criminal district court, the very court at issue here, on the basis that it was a local law. This Court rejected that claim out of hand, concluding that laws involving courts are not local but “a general act, which regulates the common good.” Id. at 1142. The Court further explained: “The argument, that a law which relates solely to the machinery of a court of justice having jurisdiction over the territory of one parish only, is a local or special law, because it does not operate throughout the State and all the parishes thereof, is perfectly preposterous, and so hollow that it cannot stand criticism.” Id. at 1143-44 (emphasis supplied). See also Polk at 1135. Act 748 concerns the judiciary and therefore does not constitute a local or special law merely because its immediate operation is confined to Orleans Parish. Plaintiff’s claim under La. Const. Art. III, sec. 13 is without merit. 7 This Court has long held that laws concerning courts are general laws. The legislature has regularly acted in conformity with, and relied upon, that consistently reiterated view. 10 III. The Preliminary Injunction Was Procedurally Improper Our holding that Act 748 is constitutional requires dissolution of the preliminary injunction. We nevertheless feel constrained to address the trial court’s decision to declare the Act unconstitutional during a preliminary injunction hearing. Louisiana Code of Civil Procedure article 855.1 requires that “[a]ll civil actions alleging that a law is unconstitutional shall be in writing and be brought in an ordinary proceeding.” A hearing on an application for preliminary injunction, by contrast, is a summary proceeding, in which certain formalities of an ordinary action do not apply, and proof may be taken on verified pleadings or supporting affidavits. La. C.C.P. arts. 2591, 3601, and 3609. Because a declaration of unconstitutionality “[i]s in effect a ruling on the merits,” such a declaration rendered during a preliminary injunction proceeding exceeds “the limited legal issues regarding the preliminary injunction,” absent the parties’ agreement to submit the merits for decision. Herman, Herman, Katz & Cotlar, L.L.C. v. State ex rel. Blanco, 08-1337 (La. 9/19/08), 990 So. 2d 737, 738. See also Calhoun v. Landry, 25-00316, p. 5 (La. 3/18/25), 403 So. 3d 521, 529 (Cole, J., concurring). The trial court’s declaration that Act 748 was “null and void” therefore exceeded the permissible scope of the preliminary injunction hearing. Considering the holding of this opinion, Judge Fuller cannot establish a likelihood of success on his constitutional claim; therefore, the preliminary injunction must be dissolved.8 CONCLUSION For the reasons assigned, the provisions of Act 748 that prospectively abolished three sections of Orleans Parish criminal district court did not require a 8 Judge Fuller observes that his petition was filed as an ordinary declaratory proceeding. But the preliminary injunction hearing itself remained a summary proceeding, and the parties did not agree to submit the constitutional merits for final adjudication at that hearing. The record also establishes some confusion in the trial court and an undue delay in it granting the state’s appeal. In these circumstances the state had a clear right to an immediate suspensive appeal under La. R.S. 13:4431, and that appeal order should have been granted without delay. 11 supermajority vote, and the challenged provisions of Act 748 of the 2026 Regular Session were constitutionally enacted. The July 15, 2026, judgment of the trial court granting a preliminary injunction and declaring Act 748 “null and void” is vacated. Judgment is rendered in favor of defendants and Judge Fuller’s claims are dismissed. Considering the impending election and the need for finality, any rehearing application in this matter shall be filed no later than 10:00 a.m. Monday, August 3, 2026. STAY LIFTED. INJUNCTION LIFTED. REVERSED AND RENDERED. 12  SUPREME COURT OF LOUISIANA No. 2026-CD-00927 JOHN T. FULLER VS. STATE OF LOUISIANA; JEFF LANDRY IN HIS OFFICIAL CAPACITY AS GOVERNOR; ELIZABETH B. MURRILL, IN HER OFFICIAL CAPACITY AS ATTORNEY GENERAL; NANCY LANDRY, IN HER OFFICIAL CAPACITY AS SECRETARY OF STATE; AND CHELSEY RICHARD NAPOLEON, IN HER OFFICIAL CAPACITY AS CLERK OF COURT FOR THE PARISH OF ORLEANS On Supervisory Writ to the 19th Judicial District Court, Parish of East Baton Rouge WEIMER, C.J., dissenting. Article V, § 15(D) of the Louisiana Constitution clearly states that “[t]he Legislature may change the number of judges in any judicial district by law enacted by two-thirds of the elected members of each house.” (Emphasis added.) Unlike the majority, I find this provision necessarily applies to courts in Orleans Parish, making Act 748—which eliminated three judge seats in Orleans Criminal District Court by fewer than two-thirds of the elected members—unconstitutional. Thus, I must respectfully dissent. Judges are called on daily to make challenging decisions based on the law or on the Constitution. Occasionally, applying the law as written can be unpopular; but partisanship, personalities, or popularity should not affect the judge’s decision. Unfortunately, judges are all too often faced with undue criticism for applying the law as written—not only from citizens, but from the government as well. One of the grievances against King George III that led to the founding of our nation over 250 years ago was that judges were adversely affected by the shifting 1 winds of politics. This grievance is reflected in the Declaration of Independence: “He has obstructed the Administration of Justice, by refusing his Assent to Laws for establishing Judiciary powers. He has made Judges dependent on his will alone, for the tenure of their offices, and the amount and payment of their salaries.” Today, the Louisiana Constitution contains that protection of judges in Article V, § 15(D). Article V, § 15(D)’s requirement of a two-thirds vote in both legislative houses serves a myriad of purposes. A supermajority vote serves to protect judicial independence and hinders political elimination of judicial seats. The difficulty in removing judge seats from a judicial district keeps the judiciary equal in power to the legislative and executive branches. Since judges in Louisiana are elected by the people of this state, a supermajority prevents the legislature from nullifying the vote of the people. The supermajority is also a safeguard against political partisanship, since it would require a consensus among the political parties to either add or subtract judge seats from a judicial district.1 The implementation of a two-thirds majority vote in both legislative houses was not arbitrarily written into Article V, § 15 (D). It was adopted from Article VII, § 34 of the 1921 Constitution, which provided that “[t]he Legislature may rearrange the judicial districts, and by a two-thirds vote of the membership of each house, may increase or decrease the number of judges in any district.” This court interpreted that prior article to mean two-thirds of the members elected to each house 1 The requirement for a two-thirds vote is not designed to protect individual judges, but to ensure separation of powers and judicial independence. There are numerous protections built into our system of justice if a judge errs. The decision may be appealed to the courts of appeal and then a writ can be taken to the Supreme Court. All judges face the electorate periodically and can be voted out of office. The Judiciary Commission, a separate constitutionally established body, can evaluate violations of the Code of Judicial Conduct by a judge who could face discipline or removal from office. But judicial independence is such an important concept in our democracy that a super majority vote is constitutionally required to prevent a particular judicial seat from being eliminated. 2 must vote affirmatively to either increase or decrease judge seats within any judicial district in this state. See State ex rel. Garland v. Guillory, 166 So. 94, 102 (La. 1935). During the Constitutional Convention of 1973, there was substantial debate over whether the divided structure of the Orleans Parish judicial districts should continue, or whether it should be restructured to resemble the other judicial districts of the state. Attempts at exempting the Orleans Parish judiciary from the protections of Article V, § 15 failed. Records of the Louisiana Constitutional Convention of 1973, Transcript Records, volume VI, pp. 786-89, August 17th, 32nd Day of the Proceedings. The intent of the framers of the Constitution was, therefore, to have the Orleans Parish judiciary protected by Article V, § 15(D), evidenced by the absence of a clear exemption from a supermajority vote with respect to Orleans Parish judges in the constitution. Article V, § 32 does not address changes to the number of judges in a judicial district; rather, it allows the Orleans Parish Civil and Criminal District Courts to continue to exist, “subject to change by law.” Article V, § 32 was written into the Constitution because the framers could not agree to the restructuring of the Orleans Parish justice system and, therefore, compromised by allowing the Orleans Parish system to remain separate, but susceptible to restructuring in the future through a legislative act rather than a constitutional amendment. The Constitution of Louisiana is the basic, fundamental law of our state emanating from the citizens of Louisiana. As the fundamental law of our state, it must be read as the primary body of law for our state. It is also a fundamental principle that all constitutional provisions must be read in pari materia, i.e., each provision must be read along with the other provisions and with the document as a whole, with each provision given meaning. See Caddo-Shreveport Sales & Use 3 Tax Comm’n v. Office of Motor Vehicles, 97-2233, p. 11 (La. 4/14/98), 710 So.2d 776, 782. Thus, Article V, § 15(D) must be read in pari materia with Article V, § 32 to determine whether Act 748 passes constitutional muster. Article V, § 15(D) does not “override” Article V, § 32, as the majority holds; the two constitutional provisions complement one another. While Article V, § 32 may be effective “notwithstanding any other contrary provision of [the Louisiana Constitution],” it is not contrary to Article V, § 15(D). The power to alter the number of judges in a judicial district is not located in Article V, § 32. The phrase “subject to change by law” in that provision does not give the legislature the power to circumvent other constitutional provisions. Professor Lee Hargrave made an in-depth analysis of Article V, § 32, wherein he stated, “the grant of power to the legislature to ‘change by law’ related to change in the continuation of the existence of the separate courts, and not a general legislative power to change all aspects of the Orleans district courts.” Lee Hargrave, The Judiciary of the Louisiana Constitution of 1974, 37 La.L. Rev. 780 (1977). This court’s earlier opinions in Davenport v. Hardy, 349 So.2d 858 (La. 1977), and State v. Francois, 445 So.2d 416 (La. 1983) establish that Article V, § 32 gives the Legislature plenary authority “to govern” the offices enumerated in the provision; however, Davenport is clear that Article V, § 32 does not give the Legislature power over what is not enumerated or what is expressly excluded, such as terms of office. Davenport, 349 So.2d at 863. Although Article V, § 32 mentions the civil and criminal district courts, it is silent as to the judges, where it specifically enumerates the sheriffs, clerks, constables, and other offices. That distinction is significant, because Article V, § 15(D) specifically addresses the 4 number of judges in any judicial district, which can only be modified by a two-thirds majority vote in both houses of the Legislature. Similarly, Francois reinforces the constitutional “separation between the civil and criminal courts in Orleans Parish. But [Article V, § 32] also reserves to the legislature the plenary lawmaking power to change this division by law.” Francois, 445 So.2d at 418. Again, Francois does not state that Article V, § 32 grants the legislature plenary authority over any judge; it only states that the legislature has plenary authority to change the division between the two district courts through enacted legislation.2 The majority applies this court’s decision in Crockett broadly to hold that the legislature’s authority under Article V, § 32 includes the authority to eliminate the judicial seats. But the majority’s ruling in Crockett was limited to the office of Clerk of Court for Orleans Parish. The elimination of a judicial seat was not before 2 The state took the position that Prof. Hargrave later changed his opinion after this court’s rulings in Davenport and Francois. However, Prof. Hargrave maintained that Article V, § 32 governed the structure of the Orleans Parish court system, and how it could be merged in the future: “In effect, the Orleans district is being served by one district court that is by constitutional provision continued as separate civil and criminal divisions until merged by an act of the legislature.” Lee Hargrave, The Louisiana State Constitution: A Reference Guide (1991), p. 91. Prof. Hargrave stated further: Other than [Article V, § 32], the constitution does not contain provisions unique to the Orleans district courts. This approach is quite different from the 1921 Constitution, which contained several sections devoted to establishing detailed rules for the Orleans courts that were often different from those applicable to the rest of the state. Id. at 92. Prof. Hargrave recognized that the framers at the 1973 Constitutional Convention had intended to make the Orleans Parish judicial districts subject to the same rules as the other judicial districts of the state, and that no other provision of the constitution other than Article V, § 32 contained language specific to the Orleans Parish judicial districts. The state argued that Davenport and Francois “confirmed that the enumerated Orleans Parish courts and offices remained subject to ordinary majority legislation,” and that this court’s decision in Crockett reiterates this principle. However, Crockett only cited to dicta from Davenport and Francois with respect to the present case. The Crockett majority ignored another constitutional provision regarding the right to vote, effectively stripping the citizens of Orleans Parish of that right. To the extent that the two constitutional articles could be at odds with one another, more specific rules prevail over the more general. See Champagne v. Ward, 03-3211 (La. 1/19/05), 893 So.2d 773, 780. In the present case, Article V, § 15(D) is clearly specific toward the manner in which judge seats are added and removed from judicial districts, and Article V, § 32 is less specific. 5 this court in that case, and Crockett was absolutely silent with respect to Orleans Parish judges and their seats, and it was silent as to Article V, § 15(D). Article V, § 15(D) does not exclude Orleans Parish. It is a statewide provision designed to shield judges from the adversity of public opinion. The majority’s ruling in Crockett with respect to Article V, § 32 cannot and does not erase or eradicate Article V, § 15(D). Article V, § 15(D) allows the number of judge seats in any of Louisiana’s judicial districts to be modified, but only by an act passed by at least a two-thirds majority vote in both houses of the legislature. To apply this court’s decision in Crockett to the current issue before the court leads to an absurd result where Orleans Parish judges are afforded less constitutional protection than all other judges in Louisiana. The legislature does have the power to “change by law” the court system of Orleans Parish, but a “law” in the form of a constitutional provision requiring a two- thirds vote to change the number of j