Monuments and Markers, LLC v. City of New Orleans and the New Orleans City Park Improvement Association

CourtLouisiana Court of Appeal
DecidedJuly 16, 2025
Docket2024-CA-0834
StatusPublished

This text of Monuments and Markers, LLC v. City of New Orleans and the New Orleans City Park Improvement Association (Monuments and Markers, LLC v. City of New Orleans and the New Orleans City Park Improvement Association) 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
Monuments and Markers, LLC v. City of New Orleans and the New Orleans City Park Improvement Association, (La. Ct. App. 2025).

Opinion

MONUMENTS AND * NO. 2024-CA-0834 MARKERS, LLC * COURT OF APPEAL VERSUS * FOURTH CIRCUIT CITY OF NEW ORLEANS AND THE NEW ORLEANS CITY * STATE OF LOUISIANA PARK IMPROVEMENT ASSOCIATION *******

APPEAL FROM CIVIL DISTRICT COURT, ORLEANS PARISH NO. 2023-13242, DIVISION “N-8” Honorable Ethel Simms Julien, Judge ****** JUDGE SANDRA CABRINA JENKINS ****** (Court composed of Chief Judge Roland L. Belsome, Judge Sandra Cabrina Jenkins, Judge Paula A. Brown) BELSOME, C.J., CONCURS IN THE RESULT.

Brian E. Sevin THE SEVIN LAW FIRM, LLC 3838 N. Causeway Blvd. Suite 3010 Metairie, LA 70002

COUNSEL FOR PLAINTIFF/APPELLANT

Donesia D. Turner Corwin M. St. Raymond Elizabeth A. Weigand Kevin C. Hill CITY OF NEW ORLEANS 1300 Perdido Street, Room 5E03 New Orleans, LA 70112

Michael L. DeShazo Marina J. Wilson Christine W. Adams Lindsey R. Pellerin DESHAZO ADAMS, LLC 832 E. Boston Street #6 Covington, LA 70433

COUNSEL FOR DEFENDANT/APPELLEE

AFFIRMED JULY 16, 2025 SCJ PAB

Monuments and Markers, L.L.C. (“Monuments and Markers”) appeal the

August 30, 2024 judgments granting a peremptory exception of no cause of action

in favor of New Orleans City Park Improvement Association (“NOCPIA”) and the

City of New Orleans (the “City”), dismissing Monuments and Markers’ claims.1

For the reasons that follow, we affirm the August 30, 2024 judgments.

FACTUAL AND PROCEDURAL HISTORY

In 1893, the Beauregard Monument Association was formed to fund and

create a monument in honor of General P.G.T. Beauregard. In 1899, the Daughters

of the Confederacy fundraised to assist in the creation of the monument. The

General P.G.T. Beauregard statue was originally erected in 1915 and removed

from public display in 2018. On December 11, 2023, Monuments and Markers

filed a petition for possession of a movable and in the alternative for declaratory

1 There are two August 30, 2024 judgments granting an exception of no cause of action. The judgment in favor of the City provides that Monuments and Markers’ case is dismissed, while the judgment in favor of New Orleans City Park Improvement Association provides that Monuments and Markers’ claims are dismissed with prejudice. When a judgment is silent as to whether it is dismissed with or without prejudice, the dismissal must be without prejudice. Doe v. Jesuit High Sch. of New Orleans, 2021-0284, p. 9 (La. App. 4 Cir. 11/10/21), 331 So.3d 426, 433. 1 relief against the City and NOCPIA. Monuments and Markers sought possession

and recognition of ownership of the General P.G.T. Beauregard statue, alleging

that it acquired rights to the statue on July 25, 2022 through a quitclaim deed

executed by the Daughters of the Confederacy.

Thereafter, the City and NOCPIA individually filed peremptory exceptions

of no cause of action, arguing that Monuments and Markers’ petition fail to state a

cause of action because the statue is a public thing that is insusceptible of private

ownership. The trial court held a hearing on the exceptions of no cause of action on

June 28, 2024. On August 30, 2024, the trial court signed two judgments granting

the exceptions of no cause of action. Monuments and Markers’ claims against the

City and NOCPIA were dismissed. This appeal timely follows.

DISCUSSION

In its sole assignment of error, Monuments and Markers assert that the trial

court erred by finding that its petition failed to state a cause of action based solely

upon this Court’s decision in McGraw v. City of New Orleans, 2016-0446 (La

App. 4th Cir. 3/29/17), 215 So.3d 319.

Exception of No Cause of Action

An appellate court reviews a trial court’s ruling on an exception of no cause

of action using the de novo standard of review because the exception raises a

question of law and the trial court’s decision is based on the sufficiency of the

petition. Stanley v. Hous. Auth. of New Orleans, 2023-0192, p. 17 (La. App. 4 Cir.

11/8/23), 377 So.3d 389, 402 (citing Herman v. Tracage Dev., L.L.C., 2016-0082,

2 p. 4 (La. App. 4 Cir. 9/21/16), 201 So.3d 935, 939). The exception of no cause of

action calls into question whether the law provides a remedy against the defendant

to anyone based upon the factual allegations in the petition. Girod Titling Tr. v.

Hermes Health All., L.L.C., 2024-0221, p. 9 (La. App. 4 Cir. 7/1/24), 401 So.3d

721, 729, writ denied, 2024-01199 (La. 12/11/24), 396 So.3d 96 (citing

Graystar Mortg., L.L.C. v. Swafford as Tr. For Gregory Swafford Fam. Tr., 2023-

0263, p. 3, (La. App. 4 Cir. 12/20/23), 382 So.3d 340, 343).

“In deciding an exception of no cause of action a court can consider only the

petition, any amendments to the petition, and any documents attached to the

petition.” Girod Titling Tr., 2024-0221, p. 10, 401 So.3d at 729 (quoting Green v.

Garcia-Victor, 2017-0695, p. 5 (La. App. 4 Cir. 5/16/18), 248 So.3d 449, 453). “A

court cannot consider assertions of fact referred to by the various counsel in their

briefs that are not plead in the petition.” Id. “The grant of the exception of no cause

of action is proper when, assuming all well pleaded factual allegations of the

petition and any annexed documents are true, the plaintiff is not entitled to the

relief he seeks as a matter of law.” Id.

Here, Monuments and Markers argue that the trial court relied on obiter

dicta from this Court’s decision in McGraw to sustain the exceptions of no cause

of action. Monuments and Markers argue that the pleadings in this matter are

distinct from the pleading in McGraw because the plaintiff in McGraw sought to

enjoin the removal of several monuments, while it is asserting ownership.

In McGraw v. City of New Orleans, the plaintiff was the founder of

Monumental Task Committee. He filed a suit for declaratory and injunctive relief

3 against the City of New Orleans and Mayor Landrieu. 2016-0446, p. 3, 215 So.3d

at 321. The plaintiff argued that the City should be enjoined from removing three

monuments, including the General P.G.T. Beauregard statue. The plaintiff further

argued that that the injunction is warranted because the City’s ordinance

unreasonably restricts his property rights. Id. at p. 3, 215 So.3d at 321-22. This

Court provided:

The Beauregard monument honors Pierre Gustave Toutant Beauregard, a Confederate general who was born in St. Bernard Parish. It depicts him in Confederate military uniform sitting astride a horse. The monument is situated on public property at the entrance of City Park within a traffic circle at the intersection of Esplanade Avenue, North Carrollton Avenue, and Wisner Boulevard. Although it was paid for by funds raised and donated by a private association, the monument was donated to the City in 1907 and publicly dedicated in 1915. Since its dedication, the monument has been maintained through private and public funds and was placed on the National Register of Historic Places in 1999.

Id. at pp. 8-9, 215 So.3d at 325.

The McGraw court considered whether the trial court erred in denying the

plaintiff’s request for preliminary injunction. This Court found that the plaintiff

failed to establish that he acquired any type of property rights in the monuments.

This Court further found that the monuments at issue, including the General P.G.T.

Beauregard statue are public things owned by the City in its capacity as a public

person. Id. at pp. 5-6, 215 So.3d at 323. This Court elaborated that “[t]he very

definition of a ‘public thing’ prohibits a private person from owning a public

thing.” Id. at p.

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Related

Band v. AUDUBON PARK COM'N
936 So. 2d 841 (Louisiana Court of Appeal, 2006)
Massiha v. Beahm
966 So. 2d 87 (Louisiana Court of Appeal, 2007)
Herman v. Tracage Development, L.L.C.
201 So. 3d 935 (Louisiana Court of Appeal, 2016)
McGraw v. City of New Orleans
215 So. 3d 319 (Louisiana Court of Appeal, 2017)
Green v. Garcia-Victor
248 So. 3d 449 (Louisiana Court of Appeal, 2018)

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Monuments and Markers, LLC v. City of New Orleans and the New Orleans City Park Improvement Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/monuments-and-markers-llc-v-city-of-new-orleans-and-the-new-orleans-city-lactapp-2025.