A N R Pipeline Co v. Richland Parish

CourtDistrict Court, W.D. Louisiana
DecidedFebruary 20, 2025
Docket3:24-cv-01403
StatusUnknown

This text of A N R Pipeline Co v. Richland Parish (A N R Pipeline Co v. Richland Parish) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
A N R Pipeline Co v. Richland Parish, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA MONROE DIVISION

ANR PIPELINE COMPANY CIVIL DOCKET NO. 3:24-cv-01403

VERSUS JUDGE DAVID C. JOSEPH

170.7942 ACRES MORE OR LESS, IN MAGISTRATE JUDGE KAYLA D. RICHLAND & WEST CARROLL MCCLUSKY PARISHES, ET AL

RULING AND PRELIMINARY INJUNCTION

On February 18, 2025, the Court heard argument and received evidence on Plaintiff ANR Pipeline Company’s (“ANR”), MOTION FOR ORDER OF CONDEMNATION AND FOR PRELIMINARY INJUNCTION authorizing it immediate entry on the Defendants’ properties (the “Motion”). [Doc. 4]. The Court, having considered the Motion and the evidence presented at the hearing, finds that the Motion is well taken and should be GRANTED. BACKGROUND ANR is a Delaware corporation that is authorized to transact business in Louisiana. [Doc. 1, p. 3]. Because ANR is engaged in the “transportation of natural gas in interstate commerce, or the sale in interstate commerce of such gas for resale,” it is a “natural-gas company” pursuant to 15 U.S.C. § 717a(6).1 ANR is the holder of

1 15 U.S.C. § 717f(h) states that “the United States district courts shall only have jurisdiction of cases when the amount claimed by the owner of the property to be condemned exceeds $3,000.” In this matter, ANR tendered a settlement offer of at least three thousand dollars for each tract of land sought and Defendant landowners did not accept these offers at the time the Complaint was filed. “A plaintiff’s offer on a property interest may constitute the minimum estimate of what constitutes just compensation” in condemnation proceedings under the Natural Gas Act. Columbia Gas Transmission Corp. v. Rodriguez, 551 F. Supp. 2d 460, 462 (W.D. Va. 2008), citing ANR Pipeline Co. v. 62.026 Acres of Land, 389 F.3d 716, 718 (7th Cir. 2004). a Certification of Public Convenience and Necessity (“Certificate”) [Doc. 1-23], issued by the Federal Energy Regulatory Commission (“FERC”) on July 25, 2024, which authorizes ANR to construct, operate, maintain, and abandon an interstate natural gas pipeline and all necessary appliances, appurtenances, fixtures, equipment, and facilities.

After the FERC Certificate was issued, ANR filed the instant lawsuit, seeking to acquire servitudes of right of use and rights-of-way over fourteen tracts of real property located in Richland and West Carroll Parishes, Louisiana (the “Property”)2 for the purpose of constructing a new 30-inch-diameter pipeline on the Property and abandoning the existing 30-inch diameter pipeline situated on the Property in connection with the Oak Grove Enhancement Project (the “Project”).

[Doc. 1]. On certain of the tracts comprising the Property, ANR also seeks to acquire temporary workspaces, which are necessary for ANR to perform construction, abandonment, and operational-related activities, including restoration or clean-up activities (the foregoing rights being sought will be referred to, collectively, as “the

2 The Complaint reflects a greater number of defendants and tracts of land. As the litigation has progressed, a number of defendants have been dismissed. ANR initially named twenty-two defendants who it believed to be the record owners of the Property. However, since the filing of the Complaint, ten landowners have entered into settlements with ANR, and twelve landowners remain (hereinafter, “Defendants”). [Docs. 1, 50, 55, 61, 69, 82]. The remaining Defendants, and their tracts of land, are as follows: George B. Franklin & Son, Inc. (Tracts No. RI-004.000, No. RI-023.000), Dairyland, LLC (Tracts No. RI-005.000, No. RI- 007.000), C&G of Winnsboro, Inc. (Tracts No. RI-015.000, No. RI-017.000, No. RI-019.000), Regan Cobb, LLC (Tract No. RI-016.000), R&S of Rayville, LLC and Scogan, LLC (Tracts No. RI-018.000, No. RI-023.100), Brian Lane Miller (Tract No. WC-026.000), Ray G. Raley and Nina G. Raley (Tract No. WC-036.000), Duck Flight, Inc. (Tract No. WC-037.000), and Donald M. Raley and Dondarosa Farms, LLC (Tract No. WC-038.000). [Doc. 84]. Proposed Servitudes”).3 Id. at ¶ 13. Further, ANR seeks rights of ingress and egress on the Property to access the Proposed Servitudes and the immediate possession of such servitudes. Id. at ¶¶ 17-18. Lastly, ANR seeks “the ascertainment and award of just compensation and damages” to the Defendant property owners.4 Id. at p. 2. On October 22, 2024, ANR filed the instant Motion, requesting that the Court

enter an order establishing a substantive right to condemnation and issue a preliminary injunction granting immediate possession of the Property. [Doc. 4-1]. Service of Notice of Condemnation has been completed against the remaining Defendants pursuant to Federal Rule of Civil Procedure 71.1(d). [Doc. 52]. A number of Defendants have not filed an answer or a notice of appearance in accordance with Federal Rule of Civil Procedure 71.1(e).

On February 6, 2025, Defendants C&G of Winnsboro, Inc., Regan Cobb, LLC, R&S of Rayville, LLC, Scogan, LLC, and George B. Franklin & Son, Inc. opposed ANR’s Motion [Doc. 78], and on February 9, 2025, ANR filed a Reply [Doc. 79]. On February 18, 2025, the Court conducted an evidentiary hearing on the Motion in Monroe, Louisiana.5 All issues pertaining to the Motion having been fully briefed and argued by the parties, the Motion is now ripe for ruling.

3 The location of each Proposed Servitude is depicted in [Docs. 84-1 to 84-14].

4 Id.

5 Participating in the hearing were Plaintiff ANR and Defendants George B. Franklin & Son, Inc., C&G of Winnsboro, Inc., Regan Cobb, LLC, R&S of Rayville, LLC, Scogan, LLC, and C. Daniel Rawls. Indicating that they have no objection to condemnation and only to valuation at this time, the following remaining Defendants waived their appearances at the hearing: Dairyland, LLC, Brian Lane Miller, Ray G. Raley, Nina G. Raley, Duck Flight, Inc., Donald M. Raley, and Dondarosa Farms, LLC. LAW AND ANALYSIS I. Jurisdiction and Venue This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1331, because this action arises under the laws of the United States, and under 28 U.S.C. § 1337, because this action arises under an Act of Congress regulating

interstate commerce. Jurisdiction is also proper in this Court pursuant to the Natural Gas Act, 15 U.S.C. § 717f(h).6 Venue is proper in this Court pursuant to 28 U.S.C. § 1391. II. Substantive Right of Condemnation ANR asks the Court to grant a preliminary injunction authorizing it to enter the Property to begin construction-related activities. Federal district courts have

consistently held that if the requirements for Rule 65 injunctive relief are satisfied, pipeline companies with the authority of eminent domain under the Natural Gas Act may, prior to the trial on compensation, be granted immediate access to the subject property to begin construction-related activities. Gulf Crossing Pipeline Co., LLC v.

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A N R Pipeline Co v. Richland Parish, Counsel Stack Legal Research, https://law.counselstack.com/opinion/a-n-r-pipeline-co-v-richland-parish-lawd-2025.