St. Charles Parish School Board v. P & L Investment Corp.

P & L Investment Corporation (P & L) (defendant) owned 45 acres of land that bordered Highway 90 (the highway) in St. Charles Parish, Louisiana (the parish). In 1972, the St. Charles Parish School Board (the school board) (plaintiff) bought 35 acres from P & L to build a new high school. The 10 acres that P & L retained included a portion in the front that bordered the highway, a small portion in the back, and a small strip on the west side that connected the front portion to the back portion. Two public streets, First Street and Second Street, provided the school board access to its parcel from the highway. In 1973, the St. Parish Police Jury, akin to a city council, swapped Second Street for P & L’s front portion. The police jury named that portion Tiger Drive and dedicated it as a public roadway. The police jury paved Tiger Drive and part of P & L’s west-side strip without objection from P & L. With P & L’s consent, the police jury or school board eventually built up and paved more of P & L’s west-side strip, and the school board referred to the paved portion of the west-side strip as part of Tiger Drive. P & L told the school board that it intended to dedicate the west-side strip to the public but never formally did. For over five years and with P & L’s knowledge, the parish and the school board maintained Tiger Drive, including P & L’s west-side strip. In 1990, P & L claimed ownership of its west-side strip. The school board filed suit, seeking a declaration that P & L had dedicated its strip for public use. However, the trial court held that P & L had not dedicated the strip, and the appellate court affirmed. The school board appealed to the Louisiana Supreme Court.