State v. Ward

The judgment of the court of appeal is reversed, and the ruling of the district court denying the defendant’s motion to quash for lack of jurisdiction is reinstated. Because the boundary between the parishes of Rapides and Grant has never been fixed pursuant to La.Rev.Stat. 50:221 et seq., a matter that is currently pending in a civil action between the parishes, the district court did not abuse its discretion in relying on secondary sources to determine jurisdiction under the doctrine of “l’erreur commune fait le droit,” or “common error.” See State v. Beard, 249 La. 811, 191 So.2d 631, 633…