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Southwest Louisiana Electric Membership Corp. v. Duck

Citations: 418 So. 2d 38; 1982 La. App. LEXIS 7788Docket: No. 82-273

Court: Louisiana Court of Appeal; July 15, 1982; Louisiana; State Appellate Court

Narrative Opinion Summary

In this case, the Southwest Louisiana Electric Membership Corporation (SLEMCO) sought supervisory writs in response to an order from the Fifteenth Judicial District Court. The order required SLEMCO to produce detailed plats showing specific locations of structures for an expropriation servitude needed to transmit electricity across properties owned by the defendants. The defendants contended that they required these plats to assess potential damages to their properties. However, SLEMCO argued that such detailed plans were irrelevant under the Louisiana Expropriation Law, particularly referencing LSA R.S. 19:2(7), which focuses on ensuring that utility structures do not unnecessarily interfere with landowners. The court initially mandated the production of the plats, but SLEMCO challenged this, asserting that the precise placement of structures could not be determined until construction commenced and that the requirement was unduly burdensome. The court concluded that SLEMCO was not obligated to provide the detailed plats, overturning the lower court's order and granting the writ. The case was remanded for further proceedings, noting that sufficient information regarding the servitude and structures had already been provided to the defendants.

Legal Issues Addressed

Evidentiary Requirements in Expropriation Proceedings

Application: The relator argued it cannot be compelled to produce plats detailing specific structure locations, as such information is not possessed at the pre-construction stage.

Reasoning: The relator cannot be compelled to produce evidence it does not possess, and the cited case, Louisiana Power and Light Co. v. Caldwell, focused on route selection rather than specific structure placement.

Expropriation Requirements under LSA R.S. 19:2(7)

Application: The court interpreted the statute to require utility companies to avoid significant interference with landowners when placing structures within an expropriated servitude.

Reasoning: According to LSA R.S. 19:2(7), the statute permits expropriation for utility companies while ensuring that such structures do not unnecessarily interfere with landowners' convenience.

Judicial Oversight in Expropriation Adjustments

Application: The court found that requiring detailed plans for each potential adjustment would result in unnecessary judicial intervention.

Reasoning: Requiring detailed disclosures for every adjustment would lead to incessant court involvement for minor changes.