Lafayette City-Parish Consolidated Gov. v. Bendel Partnership (A Partnership in Commendam)

CourtLouisiana Court of Appeal
DecidedDecember 21, 2022
DocketCA-0022-0432
StatusUnknown

This text of Lafayette City-Parish Consolidated Gov. v. Bendel Partnership (A Partnership in Commendam) (Lafayette City-Parish Consolidated Gov. v. Bendel Partnership (A Partnership in Commendam)) 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
Lafayette City-Parish Consolidated Gov. v. Bendel Partnership (A Partnership in Commendam), (La. Ct. App. 2022).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

22-432 consolidated with 22-406 and 22-521

LAFAYETTE CITY-PARISH CONSOLIDATED GOVERNMENT

VERSUS

BENDEL PARTNERSHIP (A PARTNERSHIP IN COMMENDAM), CIRCLE "A" FARM, INC., STACY ALBERT FARM, INC., AND SOUTHERN ACRES, LLC

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NUMBER C-2021-16273 “B” HONORABLE VALERIE GOTCH GARRETT, DISTRICT JUDGE

SHARON DARVILLE WILSON JUDGE

Court composed of Sylvia R. Cooks, Chief Judge, Billy Howard Ezell, and Sharon Darville Wilson, Judges.

JUDGMENT VACATED; ORIGINAL JUDGMENT REINSTATED AND AFFIRMED AS AMENDED; AND REMANDED. Pride Justin Doran Raven C. Boxie DORAN & CAWTHORNE, PLCC 521 East Landry Street Opelousas, Louisiana 70570 (337) 948-8008 Counsel for Defendant/Appellee/Cross-Appellant: Bendel Partnership, A Partnership in Commendam

Sarah Harbison PELICAN INSTITUTE OF PUBLIC POLICY 400 Poydras Street, Suite 900 New Orleans, Louisiana 70130 (504) 952-8016 Counsel for Amicus Curiae: Institute for Justice

Christen Hebert INSTITUTE FOR JUSTICE 816 Congress Avenue, Suite 960 Austin, Texas 78701 (512) 480-3936 Counsel for Amicus Curiae: Institute for Justice

Michael D. Hebert BECKER & HEBERT, LLC 201 Rue Beauregard Lafayette, Louisiana 70508 (337) 233-1987 Counsel for Plaintiff/Appellant/Cross-Appellee: Lafayette City-Parish Consolidated Government

Gregory J. Logan Lafayette City-Parish Attorney THE LOGAN LAW FIRM 700 Jefferson Street Lafayette, Louisiana 70505 (337) 406-9685 Counsel for Plaintiff/Appellant/Cross-Appellee: Lafayette City-Parish Consolidated Government

Camille Bienvenu Poche’ Karen T. Bordelon BABINEAUX, POCHÉ, ANTHONY & SLAVICH, LLC Post Office Box 52169 Lafayette, Louisiana 70505-2169 (337) 984-2505 Counsel for Plaintiff/Appellant/Cross-Appellee: Lafayette City-Parish Consolidated Government

Randall A. Smith L. Tiffany Hawkins SMITH & FAWER, LLC 201 St. Charles Avenue, Suite 3702 New Orleans, Louisiana 70170 (504) 525-2200 Counsel for Defendant/Appellee/Cross-Appellant: Bendel Partnership (A Partnership in Commendam)

Omar J. Thibeaux THE THIBEAUX FIRM 400 E. Kaliste Saloom Road, Suite 3200 Lafayette, Louisiana 70508 (337) 453-4663 Counsel for Plaintiff/Appellant/Cross-Appellee: Lafayette City-Parish Consolidated Government WILSON, Judge.

In this expropriation proceeding, both the landowner, Bendel Partnership, A

Partnership in Commendam (Bendel), and expropriating authority, the Lafayette

City-Parish Consolidated Government (LCG), appeal multiple rulings from the

trial court, which dismissed the expropriation petition, reserved the landowner’s

claims for attorney’s fees and damages, and omitted an award of costs to the

landowner. For the reasons that follow, we find no manifest error in the trial

court’s granting the motion to dismiss. However, we vacate the trial court’s May

26, 2022 judgment and reinstate the May 4, 2022 judgment and amend it to include

the following language: “Bendel Partnership’s rights regarding any claims for

attorney’s fees and/or damages are hereby reserved.” The matter is remanded for

further proceedings consistent with this opinion.

I.

ISSUES

LCG argues that the trial court erred in granting Bendel’s motion for partial

new trial, in rendering an amended judgment, and in issuing supplemental reasons

for ruling without conducting the requisite contradictory hearing on Bendel’s

purported right to a partial new trial and without specifying its reasons for granting

the motion. LCG also argues that the trial court erred in failing to limit its review

to the question of whether LCG acted arbitrarily, capriciously, or in bad faith and

in applying an elevated standard of care to LCG’s determination of public

necessity. In the alternative, LCG asserts that the trial court’s findings of fact in

holding that LCG acted arbitrarily, capriciously, or in bad faith are manifestly

erroneous. Bendel asserts that the trial court erred in failing to either grant or reserve its

claims for damages and attorney’s fees in its May 4, 2022 judgment; in omitting an

award of costs in its May 26, 2022 judgment; and in finding that LCG was required

to meet its burden of proving an abuse of discretion by clear and convincing

evidence.

II.

FACTS AND PROCEDURAL HISTORY

On December 6, 2021, pursuant to La.R.S. 19:139, et seq., LCG filed a

petition for expropriation against Bendel. Bendel is the owner of approximately

372.21 acres of immovable property located in Section 82, Township 10 South,

Range 4 East and Sections 5, 38, 39 and 42, Township 11 South, Range 4 East in

Lafayette Parish, Louisiana (the Bendel Property).1 LCG sought to expropriate the

Bendel Property for the construction of four (4) detention ponds, known as the

Homewood Drive Detention Pond Project (the Homewood Project),2 for the stated

purpose of “the improvement of drainage, as well as protection and public safety

from flooding in Lafayette Parish, Louisiana.” LCG had made a formal offer to

purchase the Bendel Property for $2,580,000.00 on September 17, 2020.

The following documents were attached to the petition: (1) the legal

description of the Bendel Property; (2) a certified copy of the ordinance declaring

that Homewood Project was a public necessity and authorizing expropriation of

property for that purpose; (3) a certificate signed by Pamela Gonzales Granger

(Granger), the supervising engineer, declaring that she had “fixed the right-of-way

1 The Bendel Property was being actively farmed pursuant to a sugar cane farm lease to Circle “A” Farm, Inc., that was effective from February 1, 2019, through January 31, 2023. 2 The Project was declared a public necessity by the Lafayette City Council and the Lafayette Parish Council under Joint Ordinance No. JO-012-2021 on March 23, 2021.

2 for the Project in a manner sufficient in my judgment to provide for the public

interest, safety, and convenience, and further, location and design of the Project are

in accordance with the best modern practices adopted in the interest of safety and

convenience of the public[;]” (4) an itemized statement of loss/damage by an

appraiser that estimated just compensation at $2,580,000.00; (5) a letter to Bendel

notifying it of the intent to expropriate the Bendel Property and return receipts of

delivery; and (6) a memo from Granger that outlined the due diligence modeling

and evaluation (the McBade memo).

On December 7, 2021, the district court signed an order declaring the Bendel

Property taken for the Homewood Project. Pursuant to the order, LCG deposited

$2,580,000.00 in to the registry of the court on December 8, 2021. On December

14, 2021, Bendel filed an ex parte motion seeking to withdraw the funds from the

registry of the court. LCG would later file an opposition to that motion.

Then, on December 23, 2021, pursuant to La.R.S. 19:139.5, Bendel filed a

motion to dismiss the expropriation petition. The motion to dismiss alleged that:

(1) the Bendel Property was not being taken for a valid public use; (2) more

property was expropriated than was needed for the Homewood Project; and (3)

Bendel was entitled to attorney’s fees, costs, and damages for the period during

which LCG possessed the Bendel Property. The hearing on the motion to dismiss

began on March 17, 2022. On March 18, 2022, Bendel moved for a continuance of

the hearing. LCG opposed the continuance.

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Lafayette City-Parish Consolidated Gov. v. Bendel Partnership (A Partnership in Commendam), Counsel Stack Legal Research, https://law.counselstack.com/opinion/lafayette-city-parish-consolidated-gov-v-bendel-partnership-a-lactapp-2022.