## Facts

- A homeowner in a single-family residential subdivision operated an annual Christmas light-and-music display that began in 1977 and grew substantially in popularity by 1982.
- The display drew large crowds who arrived by car and on foot and parked throughout the neighborhood.
- Neighboring residents alleged the crowds caused restricted access to their homes, noise, lack of on-street parking, public urination, and occasional property damage.
- The display generally ran from dusk and often continued past midnight on weekends during the holiday season.
- Neighbors sued for an injunction under Louisiana Civil Code arts. 667–669 to prevent erection or activation of the display.
- The trial court denied a preliminary injunction and later denied a permanent injunction banning the display, but ordered the display limited to 30 days and shut off nightly at 11:00 p.m.
- The court of appeal affirmed denial of injunctive relief and treated the trial court’s limits as nonbinding “parameters.”
- The Louisiana Supreme Court granted review to address neighboring-owner obligations and the propriety of injunctive relief.

## Issues

1. Whether the homeowner’s display and resulting traffic and disturbances constituted an unreasonable interference with neighbors’ enjoyment of their property under Louisiana Civil Code art. 667.
2. Whether injunctive relief was warranted, and if so, whether relief should prohibit the display or impose enforceable operational limits.

## Decision

- The court declined to prohibit the display outright and affirmed denial of a broad permanent injunction.
- The court held that, with reasonable operational limits, the display did not constitute an unreasonable interference under Civil Code art. 667.
- The court treated the trial court’s limits (30-day duration and 11:00 p.m. nightly shutoff) as binding conditions, rejecting the court of appeal’s view that they were merely advisory.

## Legal Principles

- Under Louisiana Civil Code art. 667, neighbors must tolerate ordinary inconveniences from lawful uses of adjoining property; liability arises for unreasonable interference causing serious inconvenience or damage.
- The reasonableness of interference is assessed in context, including the character of the activity, neighborhood setting, and the severity and duration of effects.
- Courts may use tailored injunctive relief—such as time and duration restrictions—to balance competing property interests when total abatement is not justified.

## Conclusion

The court balanced residential property rights and neighbor enjoyment by refusing to ban a popular seasonal display while enforcing specific limits on its duration and nightly hours as appropriate relief under Civil Code art. 667.


Rodrigue v. Copeland, 475 So. 2d 1071 (La. 1985)