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Boudreaux v. Cummings

Citations: 170 So. 3d 1002; 2014 La.App. 3 Cir. 421; 2015 La. App. LEXIS 55Docket: No. 14-421

Court: Louisiana Court of Appeal; January 13, 2015; Louisiana; State Appellate Court

Narrative Opinion Summary

In a boundary dispute between adjoining properties previously known as Agnes and Gertrude Plantations, Plaintiffs claimed additional land through thirty-year acquisitive prescription, alleging sixty years of peaceful possession before an encroachment in 2009. Initially, the trial court ruled the boundary along the original section line, but a new trial was granted based on newly discovered evidence that aligned with the Langlinais survey, favoring Plaintiffs. The Defendant appealed, challenging the new trial's grant, the admission of new witness testimony, and alleging a judicial confession by Plaintiffs. The appellate court reviewed the trial court's discretion, affirming the decision to grant a new trial under La.Code Civ. P. Article 1972(2) and 1973 due to newly discovered evidence that was neither cumulative nor discoverable with due diligence. The court also found no abuse of discretion in allowing additional testimony and rejected the claim of judicial confession, noting the subsequent lawsuit's different subject matter. The trial court's judgment was upheld, with all appeal costs assessed to the Defendant.

Legal Issues Addressed

Acquisitive Prescription under Louisiana Law

Application: The Plaintiffs claimed additional property through thirty-year acquisitive prescription, asserting uninterrupted peaceful possession for over sixty years.

Reasoning: Plaintiffs claimed uninterrupted peaceful possession of their land for over sixty years, which was disrupted in 2009 when Defendant encroached on their property.

Admissibility of Additional Witness Testimony

Application: The trial court's allowance of new and additional witness testimony at the new trial was appropriate and within its discretion.

Reasoning: The trial court's allowance of testimony from two new witnesses and additional testimony from Johnny was deemed appropriate, with no abuse of discretion found.

Boundary Disputes and Survey Evidence

Application: The trial court initially set the boundary as per the original section line but later accepted the Langlinais survey as the correct boundary after a new trial.

Reasoning: The trial court ruled in favor of Plaintiffs, determining the boundary as per the Langlinais survey and vacating the previous judgment's B-C-D boundary designation.

Judicial Confession under Louisiana Civil Code Article 1853

Application: The court found no judicial confession by Plaintiffs in a subsequent lawsuit, as the statements did not acknowledge the property line but reflected the legal status at the time.

Reasoning: Johnny clarified that he did not intend to confess regarding the property line.

New Trial for Newly Discovered Evidence

Application: The court granted a new trial based on newly discovered evidence, which could alter the case outcome, and found that due diligence was shown by Plaintiffs.

Reasoning: The trial court's decision to grant a new trial based on newly discovered evidence was deemed appropriate.

Standard for Granting a New Trial

Application: The appellate court reviewed the grant of a new trial under the abuse of discretion standard, noting the broad discretion allowed under La.Code Civ. P. Article 1973 for 'good cause shown.'

Reasoning: The trial court concluded that it did not abuse its discretion in granting a new trial based on newly discovered evidence under Louisiana Code of Civil Procedure (La.Code Civ. P.) Article 1972(2).