Plaquemines Port, Harbor and Terminal District v. State of Louisiana, Department of Transportation and Development and Plenary Infrastructure Belle Chasse, LLC

CourtLouisiana Court of Appeal
DecidedSeptember 20, 2024
Docket2024CA0099
StatusUnknown

This text of Plaquemines Port, Harbor and Terminal District v. State of Louisiana, Department of Transportation and Development and Plenary Infrastructure Belle Chasse, LLC (Plaquemines Port, Harbor and Terminal District v. State of Louisiana, Department of Transportation and Development and Plenary Infrastructure Belle Chasse, 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.

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Plaquemines Port, Harbor and Terminal District v. State of Louisiana, Department of Transportation and Development and Plenary Infrastructure Belle Chasse, LLC, (La. Ct. App. 2024).

Opinion

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2024 CA 0099

STATE OF LOUISIANA, DEPARTMENT OF TRANSPORTATION & DEVELOPMENT & PLENARY INFRASTRUCTURE BELLE CHASSE, LLC

SEP 2 0 M Judgment Rendered:

Appealed from the 19t' Ju1;icial District Court In and for the Parish of East Baton Rouge

The Honorable Tiffany Foxworth- Roberts, Judge Presiding

Dannie P. Garrett III Counsel for Plaintiff/Appellant, Baton Rouge, Louisiana Plaquemines Port, Harbor & Terminal District

10= 11 M,I I T N - pitI I I P.1111

Christopher K. LeMieux Counsel for Defendant/Appellee, Johanna Elizabeth Lambe Plenary Infrastructure Belle Hannah M. Marler Chasse, LLC New Orleans, Louisiana

e-11

v 10111 X N D1

This matter is before us on appeal by plaintiff, Plaquemines Port, Harbor &

Terminal District (" the Port"), from a judgment of the trial court granting

peremptory exceptions of prescription in favor of defendants, the State of

Louisiana Department of Transportation and Development DO an[

Plenary Infrastructure Belle Chasse, LLC (" Plenary"), and dismissing the Port' s

claims against them with prejudice. For the reasons that follow, we dismiss the

In March of 2008, the DOTD published a " Louisiana Statewide

Transportation and Infrastructure Plan — Review and Status Report," whicM

identified the Belle Chasse Tunnel project as an unfunded priority " Megaproject."

The Secretary of the DOTI) subsequently issued a separate report determining that

it was in the interest of the taxpayers to solicit a proposal for a public privall partnership to deliver the Belle Chasse Bridge & Tunnel Replacement Project,

which involved replacing the existing tunnel and adjacent bridge with a fixed 4 -

lane bridge, at an estimated cost of $122, 000, 000. 00.' Based on its studies, the

DOTD anticipated that through a public-private partnership, bridge tolls would

cover future operations and maintenance costs until the toll revenue bonds to

construct the bridge were paid. The report indicated that, at that point, the DOTD

would then assume responsibility for operations and maintenance costs through its

regular capital and operating budgets. In 2017, the DOTD applied for an " INFR,3,,

Grant" from the United States Department of Transportation requesting

50,000,000. 00 to assist in funding the project. The DOTI) submitted numerol

letters in support of its application, including a letter dated October 31, 2017, from

the Executive Director of the Pont, Maynard " Sandy" Sanders, who expressed

The DOTD' s initiation of a public-private partnership appears to be the first instance of such a partnership in the State of Louisiana.

A C4strong support" for the grant. The DOTD' s application was approved, and it w-2 I

awarded $ 45, 000,000. 00 for the the project. In June of 2018, the DOTI)

implemented a public outreach program to gain additional insights from the

traveling public within the community to ensure the project' s success.

Tunnel Replacement Public -Private Partnership Project, Plaquemines Parish, State

Project No. H.004791 (" the Projecf) pursuant to La. R.S. 48- 250.4. Work begaM

on the Project shortly thereafter in 2020.

On May 10, 2023, the Port filed a " Petition for Declaratory Judgment and

Permanent Injunction" contending that the DOTI) violated La. R.S. 48-2084. 15 bi

approving the Project without obtaining its written agreement.2The Port thus

sought a declaration that the contract was invalid, unenforceable, and null and

void, and that a permanent injunction issue enjoining the DOTI) and Plenary from

taking any further action toward completion of the Project, unless and until the

Port provides its written consent. On August 1, 2023, the Port amended its petition

to clarify that it was seeking a declaration that the contract was an absolute nullity.' The DOTI) and Plenary responded by filing peremptory exceptions of

prescription contending that the Port' s claims seeking declaratory relief and

issuance of an injunction precluding any further work on the contract, which were

2 Pursuant to the Plaquemines Parish Government Charter, the Plaquemines Parish Council serves as the sole governing authority for the Plaquemines Parish Port, Harbor and Terminal District. In September of 2020, the Port expressed concerns relating to the tolls for the Project. Thereafter, on September 24, 2020, and again on August 12, 2021, the Plaquemines Parish Council unsuccessfully attempted to pass a resolution to initiate litigation related to the Project. However, on March 9, 2023, it was able to garner enough support to pass the resolution, which resulted in the filing of the instant suit.

3Absolute nullity of a contract may be invoked by any person. La. C. C. alt. 2030. An absolutely null contract, or a relatively null contract that has been declared null by the court, is deemed never to have existed. The parties must be restored to the situation that existed before the contract was made. If it is impossible or impracticable to make restoration in kind, it may be made through an award of damages. La. C. C. art. 2033; Here, the Port is not a party to the contract.

N asserted three and a half years after the contract was entered, are prescribed based

on equitable principles of waiver, moomess, estoppel, and laches. Plenary

additionally filed peremptory -• of no cause and no right • action. A

Port opposed the exceptions of prescription contending that the contract is am

absolute nullity and is thus not subject to prescription.

Following a hearing on October 11, 2023, the trial court sustained the

were subject to a one- year prescriptive period, and that the Port failed to timely

assert those claims.' In support of its findings, the trial court relied on Airline

1990),' the 2017 letter of support by Executive Director Sanders, and the fact that I I I I M 1 11111 1111

ample opportunity to appear and object. In light of the trial court' s ruling, Plenary

withdrew its exceptions of no right and no cause of action. On October 25, 2023,

the trial court signed a judgment granting the exceptions of prescription and

Although the transcript indicates that no exhibits were filed at the hearing, the DOTI) and Plenary introduced the attachments filed in support of their exceptions with no objection. Additionally, counsel for the DOTI) presented the trial court with six photographs of the bridge construction to demonstrate " the magnitude of the project," The photographs were marked as DOTI) Exhibit I in globo and were lodged with the record in this appeal without objection.

In Airline, a public bid case where an unsuccessful bidder attempted to challenge the award of a public contract to another bidder, the Supreme Court held that:

A] n unsuccessful bidder on a public contract who wishes to obtain relief because of the rejection of its bid must seek injunctive relief at a time when the grounds for attacking the wrongful award of the contract were known or knowable to the bidder and when corrective action as a practical matter can be taken by the public body.

Airline Construction Co., 568 So. 2d at 1035.

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Plaquemines Port, Harbor and Terminal District v. State of Louisiana, Department of Transportation and Development and Plenary Infrastructure Belle Chasse, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/plaquemines-port-harbor-and-terminal-district-v-state-of-louisiana-lactapp-2024.