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Crooks v. State Department of Natural Resources
Louisiana Court of Appeal
263 So. 3d 540 (2018)
The area known as Catahoula Lake covered about 42 square miles in Catahoula Basin, Louisiana. The basin was flat land that extended outward from Little River. Little River drained and flowed into the lake area, and waters from the lake area outflowed through various outlets. A group of landowners who owned property on the banks of Catahoula Lake (the landowners) (plaintiffs) sued the state (defendant) for a determination of ownership over new land formed by water accretion. The ownership issue depended on the classification of the area known as “Catahoula Lake” as a river or a lake. The court held a trial on the matter during which expert evidence was presented based on historical records. The trial court found that in 1812 when Louisiana was admitted to the United States, the area in question constituted the banks of Little River. The river, which was a permanent water body, would seasonally overflow into the area known as Catahoula Lake. Under Louisiana law, accretion that occurs along riverbanks belongs to the riverbank owner. The trial court ruled in favor of the landowners, and the state appealed.
Rule of Law
Holding and Reasoning (Savoie, J.)
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