Entergy Louisiana, LLC v. Mudd Family Partnership, LLC

CourtLouisiana Court of Appeal
DecidedJuly 15, 2026
DocketCA-0026-0078
StatusUnknown

This text of Entergy Louisiana, LLC v. Mudd Family Partnership, LLC (Entergy Louisiana, LLC v. Mudd Family Partnership, LLC) 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
Entergy Louisiana, LLC v. Mudd Family Partnership, LLC, (La. Ct. App. 2026).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

26-78

ENTERGY LOUISIANA, LLC

VERSUS

MUDD FAMILY PARTNERSHIP, LLC, ET AL.

Consolidated With 26-81

ALLISON CLAIRE VAIL, ET AL.

**********

APPEAL FROM THE THIRTY-FIRST JUDICIAL DISTRICT COURT PARISH OF JEFFERSON DAVIS, NO. C-479-25 and NO. C-478-25 HONORABLE CRAIG STEVE GUNNELL, DISTRICT JUDGE

WILBUR L. STILES JUDGE

Court composed of Van H. Kyzar, Ledricka J. Thierry, and Wilbur L. Stiles, Judges.

AFFIRMED. Philip A. Franco Jeffrey E. Richardson Marshal A. Hevron Timothy M. Brinks Paige H. Franckiewicz Adams & Reese, LLP 701 Poydras Street, Suite 4500 New Orleans, LA 70139 (504) 581-3234 COUNSEL FOR PLAINTIFF/APPELLANT: Entergy Louisiana, LLC

Sean D. Moore Brett P. Fenasci Chynna M. Anderson Entergy Services, LLC 639 Loyola Avenue, Suite 2600 New Orleans, LA 70113 (504) 576-7048 COUNSEL FOR PLAINTIFF/APPELLANT: Entergy Louisiana, LLC

Stephen D. Polito Derek G. Hoffman Stockwell, Sievert, Viccellio, Clement & Shaddock, L.L.P. Post Office Box 2900 Lake Charles, LA 70602 (337) 436-9491 COUNSEL FOR PLAINTIFF/APPELLANT: Entergy Louisiana, LLC

David Paul Bruchhaus Jamie C. Gary Lenzi C. Hebert Thomas A. Pousson Mudd Bruchhaus & Keating, L.L.C. 517 W. College Street Lake Charles, LA 70605 (337) 562-2327 COUNSEL FOR DEFENDANTS/APPELLEES: Mudd Family Partnership, LLC, et al. Deborah Ann Berken Clement, et al.

Timothy M. Cassidy, Sr. Timothy M. Cassidy, Sr., APLC Post Office Box 1446 Jennings, LA 70546 (337) 824-7322 COUNSEL FOR DEFENDANTS/APPELLEES: Allison Claire Vail Brandon James Vail Kristie Marie Vail Schultz STILES, Judge.

Entergy Louisiana, LLC appeals the trial court’s granting of exceptions of

prematurity and the resulting dismissal of its expropriation actions filed against the

defendant landowners. For the following reasons, we affirm.

FACTS AND PROCEDURAL HISTORY

Entergy Louisiana, LLC seeks to obtain new servitudes to replace historical

transmission line servitudes that permit electric service in South Louisiana. Titling

its effort REMAP 99 Project, Entergy contacted affected landowners with offers of

compensation for the renewed servitudes as well as a “Notice Pursuant to Louisiana

Revised Statute 19:2.2.”

While certain landowners accepted Entergy’s offers of “just compensation,”

two groups of Jefferson Davis Parish landowners did not. Entergy instituted these

matters, filing Petitions for Expropriation of Personal Servitudes of Rights of Use

under two separate docket numbers. Entergy named the owners of thirteen tracts of

land as defendants in the suit assigned Docket Number C-479-25 and the owners of

four tracts of land as defendants in the suit assigned Docket Number C-478-25.

Entergy sought a judgment in its favor for the personal servitudes of rights of use for

delineated purposes, including “the right to locate, construct, operate and maintain

power lines to be constructed on a single line of structures on or over Defendants’

properties, with such accessory rights necessary for the exercise of such

servitudes . . . .”

Defendants responded with the filing of exceptions of prematurity, vagueness

and ambiguity, and no cause of action. As for the exceptions of prematurity, pertinent

here, Defendants maintained that, before suit was filed, they had received a letter

from Entergy representing that it was “intended to satisfy the requirements of La.R.S. 19.2.2.” Although the letter and its enclosures indicated that Entergy is

regulated by the Louisiana Public Service Commission, “nowhere in this document

nor any other document provided by Entergy to the Landowners lists, sets forth,

states, or identifies in any way the LPSC’s website or telephone number.”

Defendants thus argued that Entergy had not complied with the mandatory notice

requirements of La.R.S. 19:2.2(B)(6) and, in turn, the filing of its petitions was

premature pursuant to La.R.S. 19:5.1

In its opposition to the exception of prematurity, Entergy pointed out that its

notice to Defendants positively stated: “Entergy Louisiana, LLC is regulated by the

Louisiana Public Service Commission.” Entergy asserted that both the LSPC

website and its telephone number were readily identifiable by internet search. Thus,

Entergy maintained, Defendants could not reasonably establish that they suffered

any prejudice by its omission. Entergy cited Bayou Bridge Pipeline, LLC v. 38.00

Acres, 19-565 (La.App. 3 Cir 7/15/20), 304 So.3d 529, noting that a panel of this

court maintained the denial of an exception of prematurity where the expropriating

authority failed to include certain information allegedly required by La.R.S. 19:2.2

in its notice to the property owner. The panel remarked that, not only was the

information not required by the statute as it existed at the time the expropriating

authority extended its offer, but the panel also noted that the property owner could

not identify any way in which he was prejudiced by the lack of information or in

what way that information would have changed his defense of the case. Entergy

suggested that Defendants similarly demonstrated no prejudice in this case.

1 Defendants subsequently answered the petitions and filed reconventional demands, alleging that Entergy exceeded the limits of its existing servitudes. Those issues are not now before the court.

2 Following a hearing, the trial court sustained the exceptions of prematurity

and dismissed Entergy’s suits without prejudice. The trial court did not reach the

remaining exceptions.

Entergy appeals from the resulting judgments. This court granted Entergy’s

Motion to Consolidate Appeals and now considers the matter under this common

discussion. Entergy assigns the following as error:

1. The district court erred by dismissing an expropriation lawsuit as premature because La. R.S. 19:2.2 is considered directory even though mandatory language is employed.

2. The district court erred by dismissing an expropriation lawsuit as premature when the defendants suffered no prejudice from the omission of an item identified in La. R.S. 19:2.2.

DISCUSSION

Exception of Prematurity

The dilatory exception of prematurity, as provided by La.Code Civ.P. art. 926,

questions whether a cause of action is ripe for judicial determination. See Williamson

v. Hosp. Serv. Dist. No. 1 of Jefferson, 04-451 (La. 12/1/04), 888 So.2d 782. The

party pleading the exception bears the burden of proving prematurity. Id. “The trial

court’s granting of an exception of prematurity is a final judgment subject to the

manifest error standard of review unless it involves a question of law.” Barlow v.

Garber, 17-401, p. 2 (La.App. 3 Cir. 11/2/17), 230 So.3d 1002, 1004. The latter

instance requires the appellate court to review the decision de novo. Gibbs v.

Comprehensive Med. Mentoring Program, 25-116 (La.App. 4 Cir. 8/8/25), 420

So.3d 253.

Expropriation

Although both the United States Constitution and the Louisiana Constitution

authorize expropriations for a public purpose, both reflect the careful balance

3 between the extraordinary power granted the government and the substantial and

meaningful interference with the right to private property. United States Constitution

Amendment V provides that: “No person shall . . . be deprived of life, liberty or

property without due process of law; nor shall private property be taken for public

use, without just compensation.” Likewise, La.Const. art.

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Entergy Louisiana, LLC v. Mudd Family Partnership, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/entergy-louisiana-llc-v-mudd-family-partnership-llc-lactapp-2026.