Louisiana Attorney General Opinion 26-0111

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PAR
USTI
DING
USTIC
IDENTY STATE OF LOUISIANA
LIZ MURRILL ATTORNEY GENERAL
STATE OF LOUISIANA DEPARTMENT OF JUSTICE OFFICE OF THE ATTORNEY GENERAL P.O. Box 94005 BATON ROUGE, LA 70804-9005
October 20, 2026 OPINION 26-0111
The Honorable Malcolm Williams Mayor Village of Oak Ridge P.O. Box 58 Oak Ridge, LA 71264
70 MOTOR VEHICLES - Control & Regulation
La. C.C. art. 6 La. C.C. art. 10
La. C.C. art. 11 La. C.C. art. 13
La. R.S. 1:3 La. R.S. 32:8
La. R.S. 32:41, et seq. La. R.S. 32:57.1
La. R.S. 32:863 La. R.S. 32:863.1
Dear Mayor Williams,
The Village of Oak Ridge is prohibited from sending debts owed as a result of citations properly issued using automated speed enforcement devices, red light cameras, and mobile speed cameras to the Office of Debt Recovery.
You have requested an opinion regarding the interpretation and application of La. R.S. 32:49(B) to the collection of delinquent debts by the Village of Oak Ridge for traffic citations issued through the use of certain traffic control devices.
Question: Does La. R.S. 32:49(B) bar local governments from submitting their citations to the Office of Debt Recovery within the Department of Revenue?
Conclusion: Yes. La. R.S. 32:49(B) prohibits the Village of Oak Ridge from referring to the Office of Debt Recovery all final delinquent debts arising from citations issued through the use of automated speed enforcement devices, red light cameras, and mobile speed cameras.
Act 107 of the 2025 Louisiana Regular Legislative Session, in relevant part, revised La. R.S. 32:1, 43, and 45-49. Those revisions limit local parish and municipal authorities' use of certain traffic control devices and prohibit the referral of final delinquent debts from citations issued through the use of automated speed enforcement devices, red light cameras, and mobile speed cameras to the Office of Debt Recovery. Your request relates to the enactment of Subsection B to La. R.S. 32:49 which provides, "[c]itations issued through the use of automated speed enforcement devices, red light cameras, or mobile speed cameras that become final delinquent debts, pursuant to R.S. 32:8, shall not be referred to the Office of Debt Recovery within the Department of Revenue." (Emphasis added).
In your request, you interpret the phrase "final delinquent debts" by combining all three definitions relative to "debt" provided in La. R.S. 32:8(A):
(1) "Debt" means any legally collectible liquidated sum due and owed to the Department of Public Safety and Corrections, office of motor vehicles, pursuant to R.S. 32:57.1, 863, or 863.1.

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(2) "Delinquent debt" means a debt that is one hundred eighty days or more past due.
(3) "Final debt" means that the debtor has no further right of administrative and judicial review regarding the amount.
Consequently, you contend that the prohibition on referral of debts to the Office of Debt Recovery does not apply to the Village of Oak Ridge because La. R.S. 32:49(B) only applies to debts owed to the Department of Public Safety and Corrections.
As a general premise, the words of a law must be given their generally prevailing meaning. Words of art and technical terms must be given their technical meaning when the law involves a technical matter. La C.C. art. 11. Words and phrases must be read within their context and construed according to the common and approved usage of the language. La. R.S. 1:3. Laws on the same subject matter must be interpreted in relation to each other and the legislature is presumed to enact statutes in light of preceding statutes involving the same subject matter. La. C.C. art. 13. When the language of the law is susceptible of different meanings, it must be interpreted as having the meaning that best conforms to the purpose of the law. La. C.C. art. 10. If there is a conflict between two statutes dealing with the same subject matter, the statute specifically directed to the matter at issue applies. Newtek Small Bus. Fin., LLC v. Baker, 2022-01088 (La. 6/27/23), 366 So. 3d 1230, 1233-34.
Louisiana Revised Statutes 32:41-49 contain the laws pertaining to the powers of local authorities to regulate traffic on highways other than state-maintained highways within their corporate limits. Louisiana Revised Statute 32:49 governs the enforcement of local traffic ordinances, providing the specific context for the collections prohibition set forth in Subsection B. The debts referenced in La. R.S. 32:49(B) arise exclusively pursuant to local ordinances. See, La. R.S. 32:41 and 32:42. Thus, the context of the phrase "final delinquent debts" is that of debts owed to local governing authorities, not those owed to the Department of Public Safety and Corrections, despite the definitional reference to R.S. 32:8. Moreover, the plain language of La. R.S. 32:8(A)(1) states that "debt" does not apply to local governments or local ordinance, rather "debt" means a sum owed pursuant to statutes pertaining to state law and infractions thereof, La. R.S. 32:57.1, 863, or 863.1. Therefore, La. R.S. 32:8(A)(1) is not the proper context for defining a debt that applies to local governments. To construe otherwise would violate the interpretive rules requiring laws to be read within their proper context, to harmonize and reconcile laws on the same subject matter, and to provide the meaning that best conforms to the purpose of the law.
Furthermore, La. R.S. 32:8, 57.1, 863, and 863.1 are general statutes within the framework of the Louisiana Highway Regulatory Act, whereas La. R.S. 32:41-49 are specific statutes applicable to local governing authorities. It is presumed that the legislature was aware of the existing La. R.S. 32:8(A)(1) definition of "debt" when placing a prohibition on referral of debts to ODR within a statute pertaining to citations issued by parishes and municipalities by enacting R.S. 32:49(B). Had the legislature intended to prohibit DPSC from referring its debts to ODR, it is presumed it would have done so in a

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more obvious manner, not concealed within a law pertaining to enforcement of local citations and obscured by a reference to La. R.S. 32:8.
To give purpose to La. R.S. 32:49(B), "debt" must be given the generally prevailing meaning, and must be interpreted as applying to sums owed to local governing authorities. The common usage of the term "debt" is "a liquidated or certain sum of money due". Debt, Black's Law Dictionary, (12th ed. 2024). "Final" and "delinquent" are mere adjectives - modifying or describing "debt." Accordingly, the definitions of "final debt" and "delinquent debt" provided in La. R.S. 32:8(A)(2) and (A)(3) can be harmonized and reconciled with the phrase "final delinquent debts" in La. R.S. 32:49(B).
Applying the statutory rules of interpretation, it is the opinion of this office that "final delinquent debts" for the purposes of La. R.S. 32:49(B) means those sums due and owing to the local governing authority that the debtor has no further right of administrative and judicial review regarding the amount which are more than 180 days or more past due. Accordingly, La. R.S. 32:49(B) prohibits the Village of Oak Ridge from referring to the Office of Debt Recovery all final delinquent debts arising from citations issued through the use of automated speed enforcement devices, red light cameras, and mobile speed cameras.
We trust this adequately responds to your request. However, if our office can be of further assistance, please do not hesitate to contact us.
With best regards,
LIZ MURRILL ATTORNEY GENERAL
BY: AMY RICHARD EASLEY Assistant Attorney General
LM:ARE