Memorial Hall Museum, Inc. v. University of New Orleans Foundation

Frank Howard and the Howard Memorial Library Association (HMLA) owned a library in New Orleans in the late 1800s. Howard built an annex next to the library to house the library’s collection related to the Confederacy. The Louisiana Historical Association (LHA) was seeking a location to house its own collection of Confederacy materials. Howard gave a speech to the LHA in 1891 in which he stated that he would allow the LHA to use the building forever. The LHA took possession of the property in 1891, and it came to be known as the Confederacy Museum. Over the years, the LHA acknowledged that the HMLA retained ownership of the building, both during internal meetings and in negotiations with the HMLA. The HMLA eventually conveyed ownership of the property to the University of New Orleans Foundation (UNO Foundation) (defendant). The LHA’s successor, the Memorial Hall Museum, Inc. (MHMI) (plaintiff), sued the UNO Foundation, seeking to assert ownership of the property. MHMI claimed that it had either been given the property outright by Howard through his 1891 speech, or alternatively that it had acquired ownership by acquisitive prescription. The UNO Foundation asserted that the property had never been given to the LHA or its successor and that the LHA and MHMI had only had possession of the building through the permission of the true owner. The trial court held for the UNO Foundation, and MHMI appealed.