Ipf22, LLC v. Joyce Frazier

CourtLouisiana Court of Appeal
DecidedJune 6, 2025
Docket2024-CA-0772
StatusPublished

This text of Ipf22, LLC v. Joyce Frazier (Ipf22, LLC v. Joyce Frazier) 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
Ipf22, LLC v. Joyce Frazier, (La. Ct. App. 2025).

Opinion

IPF22, LLC * NO. 2024-CA-0772

VERSUS * COURT OF APPEAL

JOYCE FRAZIER * FOURTH CIRCUIT

* STATE OF LOUISIANA

*

* *******

JCL LOBRANO, J., CONCURS WITH REASONS

I respectfully concur in the results. I agree with the majority that, under our

controlling precedent in Sholes v. IPF22, LLC, 24-0552 (La. App. 4 Cir. 4/3/25), --

- So.3d ----, 2025 WL 999957, a reconventional demand seeking to annul a tax sale

based on a redemption nullity is governed by La. R.S. 47:2287, not the ten-day

answer period of La. R.S. 47:2266(B). The timeline provided by La. C.C.P. art.

1041, ninety days from service, is the appropriate procedural measure.

I write separately to stress that the ongoing invocation of La. R.S.

47:2266(B) as a peremptive bar, rather than an answer deadline, continues to cause

confusion at the trial level. When property rights are at stake, statutory precision

and procedural clarity are critical. The Legislature may wish to revisit these

provisions to explicitly distinguish answer deadlines from peremptive limits,

especially where constitutional notice rights are involved.

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Bluebook (online)
Ipf22, LLC v. Joyce Frazier, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ipf22-llc-v-joyce-frazier-lactapp-2025.