Ryan Chapman is a Deputy in the Caddo Parish, Louisiana Sheriff’s Office (CPSO). In March 2021, CPSO received a tip about the whereabouts of Chad Deloach, a wanted felon with an active arrest warrant. Chapman and two other deputies arrived at the location where Deloach was said to be hiding and saw two mobile homes on the property. William Walls exited one of the homes, and Chapman explained that the deputies were looking for Deloach. Walls gave verbal consent for the deputies to search his home, which they did without finding Deloach.
Chapman began to approach the second mobile home on Walls’ property, at which point Walls became hostile and argumentative. According to Chapman, Walls held up his phone and yelled, “I have someone you can talk to, otherwise you can get the f**k off my property.” Walls re-entered his home, and Chapman followed him inside. Chapman decided to detain Walls for officer safety while he attempted to search the second home. He handcuffed Walls and placed him in the back of a patrol unit, where he suffered a heart attack and died.
Chapman was cleared of any misconduct after an internal investigation. However, the state of Louisiana prosecuted Chapman for felony malfeasance in office by intentionally performing his duties in an unlawful manner. The State submitted a bill of particulars, explaining that Chapman (1) made an illegal, warrantless entry into Walls’ home when he followed him inside the second time, as Walls had withdrawn his consent; (2) arrested Walls without probable cause; and (3) committed battery against Walls by arresting him without legal authority.
Chapman filed a motion to quash the prosecution, arguing that the crime of malfeasance in office requires “the existence of a statue or provision of the law which delineates an affirmative duty upon the official.” The State responded by arguing that Chapman had general duties to uphold the federal and state constitution, which required him not to violate Walls’ due process rights. The trial court denied Chapman’s motion, and he appealed.
On appeal, the Court determined that “the sole issue is whether the allegations contained within the indictment and bill of particulars, taken as true, constitute malfeasance in office.” If so, then Chapman’s motion was properly denied, and vice versa. Since the State alleged only that Chapman had general responsibilities not to violate Walls’ due process rights, the Court had to judge whether the facts, as alleged, constituted an illegal search and arrest. Ultimately, the salient question was whether Walls revoked his consent for Chapman to enter his home when he told him to “get the f**k off my property.”
The Court held that Walls’ statement did not constitute a revocation of his consent to Chapman’s search. “There are multiple ways that Walls’ outburst to Chapman could have been taken. The statement, while likely verbally aggressive, gave Chapman a couple of options where reentry of Walls’ residence was concerned, one of which was for the deputy to go back inside the home with Walls to speak to someone either on the phone or in person. Another was out of concern for the officers’ safety, given the abrupt change in Walls’ demeanor. Accepting Walls’ statement at face value, the deputy’s following him back into the mobile home constitutes neither a criminal activity nor an intentional act in direct violation of Chapman’s duties as a law enforcement officer. Public safety requires some flexibility for police officers to investigate and prevent crime.
“Chapman’s ‘duty to uphold the Constitution and laws of the United States and the laws and Constitution of Louisiana,’ while written, do not create an affirmative duty specific enough to place any public officer on notice that handcuffing a person for officer safety during a consensual search for a subject with an outstanding arrest warrant based on a reliable tip or determining that consent to search has not been revoked in the midst of such a search in a situation such as that faced by Chapman, who was given an ambiguous, belligerent message subject to multiple interpretations after consent had been readily given, only one interpretation of which was the revocation of consent, will result of a charge of malfeasance in office.” The Court granted Chapman’s motion to quash.
Louisiana v. Chapman, 374 So.3d 1186 (Ct. App. La., 2023).