## Facts

- The State of Louisiana and its mineral lessee, Gulf Oil Corporation, filed suit over land located below the ordinary high-water mark of a water body in St. Mary Parish known as Six Mile Lake, part of the Grand Lake–Six Mile Lake area, adjacent to Sections 49, 50, and 68, Township 15 South, Range 11 East.
- Placid Oil Company drilled and produced from multiple wells in the disputed area (including the S.G. Todd Wells Nos. 3, 4, and 5) under mineral leases obtained from alleged private owners; J. Ray McDermott & Co., Inc. was involved as an assignee.
- The State and Gulf contended the water body should be treated as a lake, making the submerged land (and minerals) state-owned public property to the ordinary high-water mark.
- Placid and aligned private claimants contended the water body should be treated as a river or stream, arguing that the bank between ordinary low and ordinary high water marks would belong to adjacent riparian owners, supporting private title and Placid’s leases.
- The lower courts treated the water body as a river/stream and rejected the State’s ownership claim; the Louisiana Supreme Court initially agreed on original hearing.
- The Louisiana Supreme Court granted rehearing, citing the broad public significance of how Louisiana classifies and titles water bottoms in a major water body.

## Issues

1. Whether the Grand Lake–Six Mile Lake area at issue is properly classified under Louisiana law as a “lake” rather than a “river” or “stream” for purposes of fixing ownership of the bed and bank.
2. If the water body is a lake, whether the State owns the bed to the ordinary high-water mark and therefore owns the disputed tract where Placid’s wells were drilled.
3. Whether the State and its lessee may obtain an accounting for mineral production from wells drilled on land determined to be state-owned water bottom, notwithstanding defendants’ procedural and preclusion defenses.

## Decision

- On rehearing, the Louisiana Supreme Court classified the Grand Lake–Six Mile Lake area at issue as a lake, not a river or stream.
- The court held that, as a natural navigable lake, its bed and bottom are public things owned by the State to the ordinary high-water mark, so the disputed area was not privately owned bank of a river/stream.
- The court reversed the earlier determination that treated the water body as a stream and rejected private, riparian-based title theories that depended on river/stream classification.
- Because the State owned the water bottom where the wells were located, the State and Gulf were entitled to pursue recovery related to production taken from that state-owned area, including an accounting tied to the S.G. Todd wells.

## Legal Principles

- Under Louisiana law, the State, as sovereign, owns the waters and bottoms of natural navigable water bodies as public things (commonly stated in Louisiana Civil Code art. 450).
- The classification of a water body as a lake versus a river/stream affects where state ownership ends and private ownership begins:
  - For a natural navigable lake, state ownership extends to the ordinary high-water mark.
  - For a navigable river or stream, state ownership of the bed is generally to the ordinary low-water mark, while the bank between low and high water marks is generally private, though subject to public use (commonly stated in Louisiana Civil Code art. 456).
- Whether a water body is a lake or a river/stream is determined by its physical characteristics and how it functions (including whether it has a defined channel and continuous directional current associated with a stream, versus a broader expanse associated with a lake), along with historical treatment in maps, surveys, and usage.
- Doctrines that allocate alluvion and accretion to riparian owners depend on the existence of a river/stream bank; those doctrines do not transfer title to portions of a state-owned lake bottom.
- When the classification question resolves ownership of the disputed tract, defenses aimed at barring the claim (such as res judicata, judicial estoppel, or stare decisis) do not change the ownership result when the controlling law and facts require a different classification on rehearing.

## Conclusion

State v. Placid Oil Co. holds on rehearing that the Grand Lake–Six Mile Lake area in dispute is a lake, so Louisiana owns the water bottom up to the ordinary high-water mark; as a result, private riparian ownership theories tied to river/stream classification failed, and the State and its mineral lessee could seek monetary relief, including an accounting, for oil production from wells drilled on the state-owned lake bottom.


State v. Placid Oil Co., 300 So. 2d 154 (1973)