CMP, LLC v. Board of Commissioners for the Lafitte Area Independent Levee District

CMP, LLC · United States District Court for the Eastern District of Louisiana · December 17, 2025 · No. 2:24-cv-02298

Summary

The United States District Court for the Eastern District of Louisiana denies the Lafitte Area Independent Levee District’s motion to dismiss for lack of subject-matter jurisdiction based on Eleventh Amendment sovereign immunity. Applying the Fifth Circuit’s six-factor test, the court concludes that the levee district is not an arm of the state, while reserving the defendant’s alternative motion for summary judgment for a later order.

Holdings

  1. The Lafitte Area Independent Levee District is not an arm of the State of Louisiana and is not entitled to Eleventh Amendment sovereign immunity.
  2. The court denied the levee district's Motion to Dismiss for Lack of Subject Matter Jurisdiction.

Questions Presented

  1. Whether the Lafitte Area Independent Levee District is an arm or alter ego of the State of Louisiana entitled to Eleventh Amendment sovereign immunity.
  2. Whether the district court therefore lacked subject matter jurisdiction over CMP's federal taking and 42 U.S.C. § 1983 claims.

Disposition

dismissed

Cases Cited (14)

  • Ramming v. United States, 281 F.3d 158, 161 (5th Cir. 2002)(followed)
  • Krim v. pcOrder.com, Inc., 402 F.3d 489, 494 (5th Cir. 2005)(followed)
  • Home Builders Association of Mississippi, Inc. v. City of Madison, 143 F.3d 1006, 1010 (5th Cir. 1998)(followed)
  • Flores v. Pompeo, 936 F.3d 273, 276 (5th Cir. 2019)(followed)
  • Robinson v. TCI/US West Communications Inc., 117 F.3d 900, 904 (5th Cir. 1997)(followed)
  • Randall D. Wolcott, M.D., P.A. v. Sebelius, 635 F.3d 757, 762 (5th Cir. 2011)(followed)
  • Seminole Tribe of Florida v. Florida, 517 U.S. 44, 54 (1996)(followed)
  • Warnock v. Pecos County, Texas, 88 F.3d 341, 343 (5th Cir. 1996)(followed)
  • Vogt v. Board of Commissioners of Orleans Levee District, 294 F.3d 684, 688-95 (5th Cir. 2002)(followed)
  • Hudson v. City of New Orleans, 174 F.3d 677, 681-82, 687 (5th Cir. 1999)(followed)

Showing top 10 of 14.

Cited In (0)

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