## Facts

- Private landowners along the area historically known as Catahoula Lake brought a certified class action against the Louisiana Department of Natural Resources (DNR).
- The disputed area lies in the Catahoula Basin, a seasonally inundated lowland connected to Little River; water levels varied widely between high- and low-water seasons.
- Plaintiffs alleged that, at Louisiana’s 1812 statehood, the area was part of Little River’s banks rather than a separate lake bed, and that gradual sediment deposition and recession created accreted lands along those banks.
- The State treated the area as sovereign waterbottoms, leased it for oil and gas activity, and received mineral royalties.
- Plaintiffs sought a judgment fixing the boundary between private and State property, declaring class ownership of the accreted lands, and awarding inverse condemnation compensation and repayment tied to the State’s asserted ownership.
- After a bench trial relying heavily on historical maps, surveys, and expert hydrology testimony, the trial court found the area constituted the banks of Little River at statehood, awarded ownership to plaintiffs for accreted lands under alluvion/dereliction rules, and granted inverse condemnation compensation and attorney’s fees.
- DNR appealed, challenging the water-body classification, ownership consequences, and the compensation and fee awards.

## Issues

1. Whether, at Louisiana’s 1812 statehood, the area historically called Catahoula Lake was legally part of a river system (Little River and its banks) or a lake/wetland whose bed would be State-owned waterbottom.
2. Whether lands formed by gradual alluvion and dereliction in the disputed area belonged to riparian landowners or to the State.
3. Whether the State’s long-term assertion of ownership, leasing, and royalty collection constituted an inverse condemnation, and whether the trial court’s compensation and attorney-fee awards were legally proper.

## Decision

- The court affirmed the trial court’s key factual finding that, in 1812, the disputed area constituted the banks of Little River and that the river was a permanent water body that seasonally overflowed into the basin.
- The court held that, because the area was river banks at statehood, accretions formed by alluvion and dereliction belonged to the riparian landowners, not the State.
- The court affirmed, in part, the judgment recognizing plaintiffs’ ownership and the availability of inverse condemnation relief based on the State’s conduct.
- The court vacated, in part, and rendered a modified judgment adjusting aspects of monetary relief and attorney’s fees.
- A dissent would have classified the area as a lake/waterbottom, leading to different ownership results.

## Legal Principles

- Appellate review of historical, expert-driven boundary and hydrology findings applies the manifest error/clearly wrong standard.
- Ownership consequences turn on the legal classification of the water body at statehood, not later administrative treatment or designations.
- Under Louisiana civil law, alluvion and dereliction formed gradually and imperceptibly along a river’s banks accrue to the riparian bank owner.
- State ownership of navigable water bottoms and public-use considerations do not displace private ownership of accretions when the area is shown to be river banks at statehood under applicable civil-law rules.
- Inverse condemnation requires a recognized property right and State action that takes or damages that right for public purposes without just compensation; State leasing and royalty collection premised on an erroneous ownership claim may satisfy those elements.
- Monetary relief and attorney’s fees in inverse condemnation must conform to governing statutory and constitutional limits and may be modified on appeal if improperly calculated or structured.

## Conclusion

The court treated the determinative question as the area’s legal status at statehood and, accepting the trial court’s historical reconstruction that the basin was Little River’s banks, affirmed private ownership of accreted lands and inverse condemnation liability while vacating and revising portions of the compensation and attorney-fee awards.


Crooks v. State, Dep’t of Nat. Res., 263 So. 3d 540 (La. Ct. App. 3d Cir. 2018)