Barney's Family Market, Inc. v. Avoyelles Parish Police Jury

452 So. 2d 822, 1984 La. App. LEXIS 9088
CourtLouisiana Court of Appeal
DecidedJune 27, 1984
DocketNo. 83-761
StatusPublished
Cited by5 cases

This text of 452 So. 2d 822 (Barney's Family Market, Inc. v. Avoyelles Parish Police Jury) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barney's Family Market, Inc. v. Avoyelles Parish Police Jury, 452 So. 2d 822, 1984 La. App. LEXIS 9088 (La. Ct. App. 1984).

Opinion

DOUCET, Judge.

Plaintiff brought this action to obtain a writ of mandamus directed to the Sheriff of the Parish of Avoyelles and to the Avo-yelles Parish Police Jury ordering the issuance of a permit to Barney’s Family Market, Inc. to sell beer with an alcohol content of less than 3.2% in Ward 1 of Avoyelles Parish. From an adverse judgment, plaintiff appeals.

On February 22,1983, plaintiff applied to the Avoyelles Parish Police Jury to obtain a permit to sell beer at Barney’s Family Market, located in Ward 1 of Avoyelles Parish.

At its regular meeting on Tuesday, March 8, 1983, the Avoyelles Parish Police Jury denied the application on the basis of an ordinance passed following a local option election held on January 29, 1952. The ordinance relied upon by the Avoyelles Parish Police Jury was adopted after the local [824]*824option election wherein three propositions were voted upon, to wit:

(1) Shall the sale of beverages of low alcoholic content containing more than three and two-tenths percent alcohol by volume, be permitted in Ward One (1), Avoyelles Parish, Louisiana.
(2) Shall the sale of beverages of high alcoholic content, containing more than six percent alcohol by volume for consumption on the premises, be permitted in Ward One (1), Avoyelles Parish, Louisiana.
(3) Shall the sale of beverages of high alcoholic content, containing more than six percent alcohol by volume by package only and not for consumption on the premises be permitted in Ward One (1), Avoyelles Parish, Louisiana.

The voters voted against the propositions and an ordinance was enacted prohibiting the sale of any alcoholic beverages and licensing of businesses engaged therein.

Following defendant’s denial of plaintiffs application, suit was filed wherein plaintiff questioned whether the three propositions submitted to the voters on January 29,1952 prohibited the sale of beer with an alcoholic content less than 3.2% by volume.

The application submitted by plaintiff requested “a beer permit ... to sell alcoholic beverages containing more than six percen-tum (6%) of alcohol by volume”, however, plaintiffs petition seeks a permit to sell beer of an alcoholic content of 3.2%. Defendant contested plaintiffs petition emphasizing its alleged authority to control 3.2% beer, not on the grounds plaintiffs petition for mandamus was premature due to plaintiffs failure to specifically apply for a 3.2% permit. The trial court dismissed plaintiffs petition for a writ of mandamus.

Plaintiff appeals, alleging the decision of the trial court is contrary to law.

It is well established that the State of Louisiana, through its police power, has the preemptive right to regulate the sale and distribution of alcoholic beverages. State v. Gardner, 198 La. 861, 5 So.2d 132 (1941), City of Bogalusa v. Gullotta, 181 La. 159, 159 So. 309 (1935). The State may regulate the sale of alcoholic beverages under the police power so long as the regulatory laws are for a reasonable purpose. Nomey v. State of Louisiana, 315 So.2d 709 (La.1975); Nomey v. Jackson Parish Police Jury, 343 So.2d 315 (La.App. 2d Cir.1977).

Although the power to regulate traffic in alcoholic beverages is vested in the State of Louisiana, the legislature may delegate such power to political subdivisions of this state. Regulations of subdivisions of this state enacted pursuant to the authority delegated by the state cannot exceed the grant of authority and must fall when they conflict with state law.

In 1950, the Legislature included the local option provision in Revised Statutes 26:581, et seq. Revised Statute 26:588, as adopted in 1950, prohibited the adoption of any ordinance, which would prohibit the sale or use of alcoholic beverages continuing not more than three and two-tenths percent alcohol by weight. The Legislature refused to provide to local governing bodies the right to prohibit the sale of 3.2% beer.

It was obvious to the Avoyelles Parish Police Jury in 1952, when the local option election was called, that prohibiting the sale of 3.2% beer could not be done because of the provisions of R.S. 26:588. Accordingly, the three propositions submitted to the voters did not present for their determination whether to prohibit the sale of alcoholic beverages of 3.2% or less of alcohol by weight.

However, the ordinance adopted by the Avoyelles Parish Police Jury on February 13, 1952 purports to prohibit the sale of alcoholic beverages having an alcohol content of less than three and two-tenths percent alcohol by weight, i.e., beer.

Louisiana R.S. 26:588, which prohibited local prohibition of beverages containing [825]*8253.2 percent alcohol or less, was repealed in 1980. Since 1980, the Louisiana Legislature has extended to local governing authorities the power to regulate the sale, storage and distribution of all alcoholic beverages, regardless of the percentage of alcohol.

Aside from the repeal of La.R.S. 26:588 in 1980, defendant contends that the Avo-yelles Parish Police Jury had a special delegation of authority by the State to control the sale of all alcoholic beverages in Ward One in 1952, regardless of percentum of alcohol contained. In 1974 the Louisiana Legislature enacted La.R.S. 26:601 (now repealed) which specifically listed Ward One, Avoyelles Parish, Louisiana, as excluded from the provisions of Louisiana R.S. 26:588. However, La.R.S. 26:588 was held unconstitutional in Tolar v. State, 315 So.2d 22 (La.1975).

In addressing La.R.S. 26:588, which provided that beverages of 3.2% alcohol could not be prohibited except where such prohibition was in effect prior to 1948, the court in Tolar, supra, noted, inter alia, that the legislature is incapable of reviving otherwise invalid local option liquor ordinances.

With regard to appellant’s contention that the Avoyelles Parish Police Jury is without authority to regulate alcoholic beverages of 3.2 percent, we note a similar argument was rejected in Rapides Merchants Association v. Rapides Parish, 421 So.2d 955 (La.App. 3rd Cir.1982) writ denied 426 So.2d 174 (La.1983), wherein this court observed:

the right of local governments to control the sale of 3.2 beer has had a long and interesting history in both the legislative and judicial branches of government. Since 1948 by Act No. 372 of the 1948 Regular Session of the Louisiana Legislature,4 the State has attempted to reserve unto itself the right, at least in part, to regulate the sale, manufacture, production, etc., of 3.2 beer. Since that time Courts of this State have universally held that Section 5885 prohibited local governing bodies from regulating beverages containing 3.2 percent alcohol by weight or less.
State v. Sissons, 292 So.2d 523 (La.1974); Harper v. State, Department of Revenue, 328 So.2d 669 (La.1976); Helverson v. Rapides Parish Police Jury, 391 So.2d 516 (La.App. 3rd Cir.1980), writ denied 396 So.2d 1325 (La.1981).
By Act No. 663 of the 1980 Regular Session of the Louisiana Legislature, the Legislature repealed Section 588 in its entirety, and thereby, in our opinion, obviously intended to open the door to local political subdivisions to regulate and/or prohibit beverages containing under 3.2 percent alcohol.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Opinion Number
Louisiana Attorney General Reports, 2004
Lorning v. Alden
809 So. 2d 526 (Louisiana Court of Appeal, 2002)
A to Z Paper Co. v. State, Department of Environmental Quality
770 So. 2d 445 (Louisiana Court of Appeal, 2000)
Papa v. City of Shreveport
661 So. 2d 1100 (Louisiana Court of Appeal, 1995)
Lasalle State Bank v. Nugent
508 So. 2d 658 (Louisiana Court of Appeal, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
452 So. 2d 822, 1984 La. App. LEXIS 9088, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barneys-family-market-inc-v-avoyelles-parish-police-jury-lactapp-1984.