Opposition Brief — East First First Street, LLC v. Board of Adjustments (No. 08-1078)

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Bn The eer awe deel set apn eet ate See

Supreme Court of the United States

EAST FIRST STREET, L.L.C. AND

M & B RENTALS OF AMERICA, L.L.C.,

Petitioners,

Vv.

BOARD OF ADJUSTMENTS AND CITY OF THIBODAUX,

Respondents.

On Petition for Writ of Certiorari to the

Loutstana Court of Appeal for the First Circutt

BRIEF IN OPPOSITION

CLAYTON E.. LOVELL

Counsel of Record

DUVAL, FUNDERBURK, SUNDBERY,

LOVELL & WATKINS

101 WiLson AVENUF

P.O. Box 3017

Houma, LA 70361

(985) 876-6410

Counsel for Respondents

April 23, 2009

Becker Gallapher - Cincinnan OH = Washagtron, DC - S00 890 SOO]

i

QUESTIONS PRESENTED

1. Does a true conflict exist between this Court’s

decision in Lucas v. South Carolina Coastal Council,

505 U.S. 1003 (1992), and the decision below from a

Louisiana intermediate appellate court that a

particular local zoning classification constitutes a

background principle under state law?

2. Does a true conflict exist between the decision

below from a Louisiana intermediate appellate court

that a particular local zoning classification constitutes

a background principle under state law and decisions

from other courts, including intermediate appellate

courts of other states?

ll

PARTIES TO THE PROCEEDINGS

Plaintiffs-Appellants:

Kast First Street, L.L.C.

M & B Rentals of America, L.L.C.

Intervenors-Appellants:

Cornel Martin

Cynthia Graham Martin

Defendants-Appellees:

Board of Adjustments

City of Thibodaux

Thibodaux City Council

Intervenors-Appellees:

Guy Diebold

Catherine Diebold

David Middleton

Francine Middleton

Chester Boudreaux

Anne Boudreaux

Mary Duplantis

ill

TABLE OF CONTENTS

(Qucutions FRORNBGOE 4 5 ibe ss bk ova ee een ]

Parties to the Proceedings ................... il

ee er I oe ee ce eae ill

ee Oe Fae a ek hE ck ee iv

statement of the Case .. ck. cece ce ees 1

| Rae rs ne AER Ee POER TET Sant Pus ea 3

Reasons for Denying the Petition .............. 5

1. The decision below does not. conflict with the

Court's decision in LUCds ...... 2.6. een: 5

2. The decision below does not conflict with

other cases cited by Petitioners .......... g

3. The issue decided by the court below does

not merit this Court’s review ........... 1]

4. The decision below was correctly decided . 12

COTO on OO oa a eee ee 14

iV

TABLE OF AUTHORITIES

CASES

Avenal v. State,

886 So.2d 1085 (La. 2004), cert. denied,

544 U.S. 1049 (1995) ........ 2,6, 7, 10, 24, 12

Bowditch v. Boston,

Be ae ee oh oie ke ewe ee ee 4

City of Sherman, Texas v. Wayne,

266 S.W.3d 34 (Tex.App.- Dallas [5 Dist.]

RI a Aer BP n/a a eee la riage A nee ae 9,10

East First Street, L.L.C. v. Bd. of Adjustments,

986 So.2d 257 (Table), 2008 WI. 2567080 (La.

App. 1* Cir.), writ denied, 996 So.2d 1111

CRE YS Pen Piete-o he Oe ana me a pt a 2,6, 7, 12, 18

Esplanade Props., LLC v. City of Seattle,

307 F.3d 978 (9"" Cir. 2002), cert. denied,

Boo Uae. DOCS) 5 oe i ie ee aes 10,11

Hernandez v. City of Lafayette,

399 So.2d 1179 (La. App. 3™ Cir.), writ denied,

401 So.2d 1192 (La. 1981), appeal dismissed,

IN Fe. Pe RIE Boe Se a ee ee ee is

King v. Caddo Parish Comm'n,

€89 So.2d 410 (La. 1996) ... 2.2... ...450- 7,12

Lucas v. South Carolina Ceastal Council,

wo 05. 1008 (1982) 2... 6 ens _ passim

Vv

M.J. Farms, Ltd. v. Exxon Mobil Corp..,

Wee B0.20 16 Cle. BOOB)... 2). eee tees 1,5

Palazzolo v. Rhode Island,

ee Se. wee ee eee wcwxpees 8

Pennsylvania Coal Co. v. Mahon,

te SA Pe ED cide ee a ewe ee eee 8

Robertson v. Jefferson Parish,

465 So.2d 787 (La. App. 5" Cir. 1985) ...... 13

St. Tammany Manor, Inc. v. Spartan Bldg. Corp.,

509 So.2d 424 (La. 1987) ... 2... eee J

Standard Materials, Inc. v. City of Slidell,

700 So.2d 975 (La. App. 1*' Cir. 1997)... 2... .. 13

State, Dep’t of Social Servs. v. City of New Orleans,

676 So.2d 149 (La. App. 4" Cir. 1996) ...... 13

Steel v. Cape Corp.,

677 A.2d 634 (Md. App. 1996) ........... 9, 10

Tahoe-Sierra Pres. Council, Inc. v. Tahoe Reg’l

Planning Agency,

ee eee CY on cent ewe ces cewes 8

United States v. Pactfic R. Co.,

Rae ia. eae CR d Pg es. os cae Ooh ewe eee 4

CONSTITUTION

La. Const. Art. 1, 8 4 (B)(1)

tr

vi

STATUTES

ae Oy 1,5

RULES

SS ee 11

OTHER AUTHORITIES

Blum and Ritchie, Lucas’s Unlikely Legacy: The

Rise of Background Principles as Categorical

Takings Defenses, 29 HARV. ENVTL. L. REV. 321

NS in RS ak na Ma a 6,8

Gressman et al, SUPREME COURT PRACTICE, § 3.14

SEMI Bet Pye Rann te ee Ae So oS Sg ee

1

STATEMENT OF THE CASE

Respondents here address’ the factual

misstavements in the Petition at pp. 3-13:

Page 3: This case does not involve a review of the

Louisiana Supreme Court’s writ denial. Petitioners

overlook the fact that the Louisiana Supreme Court’s

order declining to review the decision of the Louisiana

First Circuit Court of Appeal is not a decision on the

merits, much less a decision on “an important question

of federal law.” The Louisiana Supreme Court’s denial

of a supervisory writ has “no precedential value.” M.d/.

Farms, Ltd. v. Exxon Mobil Corp., 998 So.2d 16, 24

(La. 2008); St. Tammany Manor, Inc. v. Spartan Bldg.

Corp., 509 So.2d 424, 428 (La. 1987). The Louisiana

Supreme Court’s order declining to review the decision

below is also not the judgment reviewable herein

under 28 U.S.C. § 1257(a). The reviewable judgment

is the First Circuit’s judgment on the merits.

(;ressman et al, SUPREME COURT PRACTICE, § 3.14 at

180 (Ninth FEd.).

Page 3: The properties “at issue” are not “five

adjacent small parcels in Thibodaux, Louisiana,” as

described by Petitioners. The Petitioners in this

Court, East First Street, L.L.C. and M & B Rentals of

America, L.L.C., own only one of the five tracts that

were involved in the zoning classification reviewed by

the district court and by the Louisiawa First Circuit

Court of Appeal.

Page 3, 5: Petitioners incorrectly identify “Corne|

and Cynthia Martin” as Petitioners herein.

2

Page 3, 12: Petitioners claim it is undisputed that

the R-1 zone has “totally devalued” their tract (page 3)

and “has destroyed” its value (page 12). The tract can

continue to be operated as a filling station, although

that might not be the most advantageous economic use

of the property.

Page 4-5: References to Properties 2 through 5 are

irrelevant because neither of the Petitioners owns any

of these tracts.

Page 6-8: References to the zoning and variance

history of properties not owned by Petitioners are

irrelevant.

Page 11: Petitioners incorrectly state that the

district court “did not address the petitioners’

takings/damages claim.” ‘The district court did

address Petitioners’ state law takings and damages

claims, as specifically found by the Louisiana First

Circuit Court of Appeal. East First Street, L.L.C. v.

Bd. of Adjustments, 986 So.2d 257 (Table), 2008 WL

2567080 at * 3n. 2 (La. App. 1“ Cir.), writ denied, 996

So.2d 1111 (2008).'

' Petitioners did not raise any takings claim under federal law;

they did raise takings and damages claims under Louisiana law

Art. I, § 4.(B)(1) of the Louisiana Constitution of 1974 provides

that property “shall not be taken or damaged by the state or its

political subdivisions except for public purposes and with just

compensation paid..... Louisiana law recognizes an action for

buth a taking and for a damaging under this constitutional

provision. See Avenal v. State, 886 So.2d 1085, 1113 (La. 2004),

cert dented, 544US. 1049(2005)(Weimer, J, concurring)(“Under

Louisiana law, a damage claim is compensable although it 1s not

a taking”)

3

Page 12: Petitioners’ statement that, prior to the

decision below, no Louisiana court had ever allowed a

municipality to change the zoning of a commercial

building to residential-only is irrelevant because

Petitioners did not challenge the validity of the zoning

in the Petition.

INTRODUCTION

The Petition is based entirely on a convenient

distortion of the Court’s opinion in Lucas v. South

Carolina Coastal Council, 505 U.S. 1003 (1992). Lucas

recognized an exception to the rule that a state must

compensate a landowner for a regulatory taking that

deprives the owner of all economic value. For the

exception to apply, the Court required that the

regulation “must inhere in the title itself, in the

restrictions that backyround principics of the State’s

law of property and nuisance already place upon land

ownership.” Jd. at 1029. Lucas also required that

these background principles must produce the same

result as would flow from any one of three sources:

first, the State’s law of private nuisance, second, the

state’s power to abate nuisances that affect the public

generally; or, third, “otherwise.” It is the application of

this “otherwise” source of background principles that

Petitioners have distorted. /d.

Justice Scalia explained the “otherwise” source of

background principles in a footnote in Lucas:

The principal ‘otherwise’ that we have in mind

is litigation absolving the State (or private

parties) of liability for the destruction of ‘real

and personal property, mn cases of actual

necessity, to prevent the spreading of a fire’ o1

4

to forestall other grave threats to the lives and

property of others. Bowditch v. Boston, 101

U.S. 16, 18-19, 25 L.Ed. 980 (1880); see United

States v. Pacific R. Co., 120 U.S. 227, 238-239,

7S.Ct. 490, 495-496, 30 L.Ed. 634 (1887).

Id. at 1029 n. 16.

It could not be more clear that the “grave threats”

source of background principle is only one of the three

ways that a government may defend against this type

of regulatory takings claims. Lucas also specifically

armed governmental agencies with defenses based on

private or public nuisance laws. Yet [Petitioners

entirely ignore this fact. Instead, they read Lucas as

limiting the scope of background principles to “grave

threats” alone.’ Not only is their compression into one

source of the three sources of background principles an

obvious distortion of Lucas, but the court below did not

even base its ruling on the “grave threats” defense.

Petitioner’s sole Question Presented attempts to

read the “grave threats” defense into this case. But it

doesn’t belong here, and this case doesn’t belong in

this Court.

* Petitioners claim that “background principles are principles that

1) ‘forestall’ ‘grave threats to the lives and property of others’ and

2) are ‘cases of actual necessity.” Petition at 16. Applying their

incomplete construct to this case, Petitioners argue that,

“lalpplying Lucas’ threat-forestalling principle to Che instant case,

a zoning law that places a house-only zone over a gas station and

demies the owner the ability to renovate his building and

modernize his business is not an ‘actual necessity’ and does not

prevent any ‘grave threats ” /d

5

REASONS FOR DENYING THE PETITION

Petitioners invite this Court to “establish once and

for all that the lower courts must follow Lucas’

forestalling grave threats standard.” Petition at 23.

But they have cited no cases where a court improperly

applied Lucas. Instead, Petitioners rely on cases

where “grave threats” were not involved, as well as

cases where courts properly found a “grave threat.”

1. The decision below does not conflict with

the Court’s decision in Lucas.

Petitioners state that the “Louisiana Supreme

Court, a court of last resort,” has decided “an

important question of federal law” that conflicts with

Lucas. Petition at 14.° Petitioners’ “conflict”

argument is based on their mischaracterization of

Lucas as limiting the source of background principles

to “grave threats” alone. Petition at 16. Neither this

Court in Lucas nor the Louisiana First Circuit in this

case limited the application of “background principles”

to cases involving “grave threats.” Instead, the

Louisiana First Circuit relied on one of the other two

sources of background principles approved in Lucas -

i.e., a State’s nuisance or zoning laws. There is simply

no conflict between the two decisions

As previously noted, the Louisiana Supreme Court's order

declining to review the decision below is neither a decision on the

merits, MJ. Furms, Ltd vo. Exxon Mob ( ‘orp 998 So. 2d 16, 24

(la ZOOS), nor the judement reviewable herein under 08 USC

8 1257(a). The reviewable pudyment is the First Circuit Court of

Appeal’s judgement on the merit Grressman et al, SUPREMI

COURT PRACTICE, § 3.14 at L180 (Ninth Ed.)

6

The Louisiana appellate court found — as Lucas

and the Court’s other decisions allowed it to do — that

the City of Thibodaux did not owe Petitioners

compensation because the city’s 1979 zoning change to

a residential classification “is a background principle

that is a defense to recovery of damages under

Louisiana’s takings law.” East First Street, L.L.C. v.

Bd. of Adjustments, 986 So.2d 257 (Table), 2008 WL

2567080 at * 5 (La. App. 1* Cir.), writ denied, 996

So.2d 1111 (La. 2008). The First Circuit discussed

Lucas, and explained:

Further, there is widespread agreement among

the members of the Supreme Court that ‘some

valid zoning and land use regulations are

background principles that bar any takings

claim.’ Blum and Ritchie, Lucas’s Unlikely

Legacy: The Rise of Background Principles as

Categorical Takings Defenses, 29 Harv. Envtl.

L. Rev. 321, 356 (2005).

Id. at * 4."

The First Circuit then examined the Louisiana

Supreme Court’s decision in Avenal v. State, 886 So.2d

1085, cert. denied, 544 U.S. 1049 (1995), which

addressed federal and state takings claims by a group

of Louisiana oyster fishermen. It was undisputed that

* Another example of Petitioners’ distortion of the sources of

background principles is found tn their statement that “the

lawsiana courts herein never mentioned the Lucas background

principle standard.” Petition at 22. The correct version of the

statement would be that the First Circuit did not mention

Petitioners’ limited version of background prinjples. See Hast

First Street, 2008 WL 2567080 at © 4-5

7

the state’s coastal restoration/freshwater diversion

project lowered the salinity of water over areas that

the state leased to oyster fishermen. In the decision

below, the First Circuit quoted from the Louisiana

Supreme Court’s rejection in Avenal of the fishermens’

takings claims under state and federal] law:

iC]ompensation is not owed if the state action is

in accordance with a ‘background principle’ of

the state’s property law that already prohibit[s]

the landowner from the use he claims was

taken, or is undertaken in the exercise of the

state’s police power.

East First Street, 2008 WL 2567080 at * 5, quoting

Avenal v. State, supra at 1108 n. 28.

The First Circuit then decided, as a matter of state

law, that the 1979 zoning classification is “a

background principle that is a defense to recovery of

damages under Louisiana’s takings law.” Jd. The

First Circuit noted that zoning “is a legislative

function, the authority for which flows from the police

power of governmental bodies,” quoting King v. Caddo

Parish Commission, 719 So.2d 410,418 (La. 1998), and

observed that nothing in the record “suggests that the

zoning is somehow invalid or that it was done for a

malicious or improper purpose.” East First Street,

2008 WL 2567080 at * 5. If the Louisiana First Circuit

had held that one or more of the Lucas exceptions

should never apply in a regulatory takings case, a

8

conflict between this case and Lucas might exist.® But

that is certainly not the case here.

The First Circuit’s finding that a zoning ordinance

qualified as a background principle did not emerge as

might a rabbit from a hat. It was rooted in this

Court’s previous statements concerning takings

claims. For example, in Palazzolo v. Rhode Island, 533

U.S. 606, 627 (2001), Justice Kennedy, writing for the

majority, recognized that the right to improve property

“is subject to the reasonable exercise of state authority,

including the enforcement of valid zoning and land-use

restrictions,” quoting Pennsylvania Coal Co. v. Mahon,

260 U.S. 393, 413 (1922). The late Chief Justice

Rehnquist quoted this passage from Palazzolo in his

dissenting opinion in Tahoe-Sierra Preservation

Council, Inc. v. Tahoe Regional Planning Agency, 535

U.S. 302, 352 (2002)(Rehnquist, C.J., dissenting).°

° In the cited example, a conflict might not even exist because the

case below did not present federal takings claims.

* See Blumm and Ritchie, Lucas’s Unlikely Legacy. The Rise of

Background Principles as Categorical Takings Defenses, 29 HARV

ENVTL. L.REV. 321, 356 (2005), noting that Palazzolo

did not state that statutes and regulations could never

amount to a background principle. Instead, it recognized

that at least some statutes are background principles

sufficient to defeat a takings claim at the threshold stage

Justice Kennedy’s Palazzolo opinion declared that

‘{tuhe nght to improve property, of course, is subject to the

reasonable exercise of state authority, including the

enforcement of valid zoning and iand-use restrictions.’

Further, Chief Justice Rehnquist's dissent in Tuhve

Sterra, joined by Justices Thomas and Sealia, cited this

passage from Palazzolo, thereby demonstrating

9

Thus, the decision below does not conflict with

Lucas.

2. The decision below does not conflict with

other cases cited by Petitioners.

Petitioners claim that the decision below conflicts

with a decision from the Texas Court of Appeals, the

Maryland Court of Special Appeals,’ the U.S. Ninth

Circuit Court of Appeals, and the Louisiana Supreme

Court. Petition at 14. This claim is meritless.

Neither the Texas case, City of Sherman, Texas v.

Wayne, 266 S.W.3d 34 (Tex.App.- Dallas [5“ Dist.]

2008), nor the Maryland case, Steel v. Cape Corp., 677

A.2d 634 (Md. App. 1996), mentions, much less relies

on, the “grave threat” defense or any other type of

widespread agreement among the Court’s members that

at least some valid zoning and land use regulations are

background principles that bar any takings claim.

Although the Palazzolo decision declined to decide when

legislation can be considered to be a background principle

of state law, the Court made clear that ‘[tlhe

determination whether an existing, general law can limit

all economic use of property must turn on objective

factors, such as the nature of land use proscribed.”

(footnotes omitted).

’ Petitioners incorrectly describe the Maryland Court of Special

Appeals as Maryland’s court of last resort. Petition at 14, 17. In

fact, it 1s that state’s intermediate appellate court, and the

Maryland Court of Appeals is the court of last resort in that state

http://www.courts state.md.us/coappeals/index. html (visited April

21, 2009). The Supreme Court of Texas, not the Texas Court of

Appeals system, 1s that state’s court of last resort for civil matters.

http://www supreme.courts state tx.us (visited Apml 21, 2009)

10

background principle.” In addition, the Maryland

intermediate court specifically limited its holding in

Steel to the very unique facts of that case. We assume

that Petitioners mentioned these two cases because

the court in each case found that a taking occurred

under state law and that the governmental entity

owed compensation. But that is not the issue that

Petitioners ask this Court to consider.

Neither of Petitioners’ other two _ so-called

“conflicting” cases actually do so. Both the Louisiana

Supreme Court’s decision, Avenal v. State, supra, and

the Ninth Circuit’s decision, Esplanade Properties,

LLC v. City of Seattle, 307 F.3d 978 (9 Cir. 2002),

cert. denied, 539 U.S. 926 (2003), found there was no

taking; therefore, those decisions did not include a

ruling on whether background principles applied.

Petitioners rely on the Louisiana Supreme Court’s

implicit characterization in Avenal of the state’s

freshwater diversion project as a background principle

because “the freshening of these waters in order to

prevent further coastal erosion and save Louisiana’s

coast is a matter of ‘actual necessity’ as it will ‘forestall

la] grave threat to the lives and property of others.”

Petition at 20, quoting Avenal v. State, supra at 1108

n. 28, quoting Lucas, supra at 1029 n. 16. But this

statement of the Louisiana high court was dicta, as the

* Petitioners admit that “the court in Ciiy of Sherman v. Wayne

did not discuss a background principles defense.” Petition at 19.

* Steel v. Cape Corp., 677 A.2d 634, 651 (Md. App. 1995"“We

would be remiss if we did not note that our holding, 7e., that the

statutory scheme,as applred in the instant case, where the existing

zoning ts OS. is unconstitutional, is limited to the instant case.”)

(emphasis in orignnal)

11

court had, earlier in its opinion, found that the

diversion program “did not deprive the plaintiffs of all

economically beneficial use of their property,” and thus

did not constitute a taking under state law. Avenal,

supra at 1107.

Hewing to their incomplete definition of

background principles, Petitioners claim that the

Ninth Circuit in Esplanade Properties “restated Lucas’

definition of background principles being ‘cases of

actual necessity, to prevent the spreading of a fire or

to forestall other grave threats to the lives and

property of others.” Petition at 21, quoting Esplanade

Properties, supra at 987. Petitioner’s incomplete

statement of the Ninth Circuit’s larger quotation from

Lucas — which included this Court’s entire discussion

of background principles — cannot hide the plain fact

that Esplanade Properties does not conflict in any way

with the Louisiana First Circuit’s decision in this case.

There is no indication from the four supposedly

“conflicting” cases that any of those courts — or this

Court -- would reach a different result than did the

Louisiana First Circuit in this case. This case does not

satisfy the Court’s criteria for reviewing a case on the

basis of conflict. Sup.Ct. R. 10.

3. The issue decided by the court below does

not merit this Court’s review.

Petitioners have attempted to transform this fact-

specific case addressing claims under Louisiana law

into one involving “an important question of federal

law.” Petition at 14. Evenifthis case did present such

a question, it would not be an appropriate medium for

the Court to review the issue. If, as Petitioners

12

contend, this Court has not explicitly decided whether

a “value-confiscating, use-changing zoning provision is

a background principle,” Petition at 17, that fact

weighs against this Court’s review. The issue of what

a Louisiana court considers to be a background

principle under Louisiana law is not an issue that

merits the Court’s attention. The issue is not only

fact-intensive, it will affect no litigants outside the

State of Louisiana and few within it.

‘The decision below is only the second reported

Louisiana decision that addresses the question of what

constitutes a background principle in a takings case.

The first such decision, Avenal v. State, supra,

addressed the issue in dicta. The decision below is an

unpublished unanimous opinion that affirmed the

decision of the trial court (which had, in turn, affirmed

the decision of the Board of Adjustments of the City of

Thibodaux). Given these circumstances, the issue of

background principles is not mature under Louisiana

law, and does not merit the Court’s review.

4. The decision below was correctly decided.

Petitioners’ substantive quarrel is with the

Louisiana First Circuit’s application of Lucas to state

law claims. The First Circuit correctly found that

valid zoning and land use regulations are a defense to

this type of regulatory takings claim.

The First Circuit held that zoning “is a legislative

function, the authority for which flows from the police

power of governmental bodies.” East First Street

L.L.C., 2008 WL 2567080 at * 5, quoting King v. Caddo

Parish Comin, 719 So.2d 410, 418 (La. 1998).

Accordingly, the court below correctly found that the

i3

City of Thibodaux’s zoning ordinance was a

background principle under Louisiana law, based on

the fact that (1) it had been in place since 1979, and (2)

the record did not suggest that the zoning was either

invalid or that it had been enacted for a malicious or

improper purpose. Kast First Street, 2008 WL 25670890

a S.

Louisiana law makes clear that the fact that a

zoning ordinance does not permit an owner the most

advantageous economic use of his or her land does not

render the ordinance invalid. Hernandez v. City of

Lafayette, 399 So.2d 1179, 1185 (La. App. 3™ Cir.), writ

dented, 401 So.2d 1192 (La. 1981), appeal dismissed,

455 U.S. 901 (1982). And an unconstitutional taking of

property does not result merely because an owner is

unable to develop the property to its maximum

economic potential. Standard Materials, Inc. v. City of

Slidell, 700 So.2d 975, 984 (La. App. 1° Cir. 1997);

State, Dep't of Social Servs. v. City of New Orleans, 676

So.2d 149 (La. App. 4" Cir. 1996); Robertson v.

Jefferson Parish, 465 So.2d 787, 791 (La. App. 5" Cir.

1985).

Because the Louisiana First Circuit Court of

Appeal applied the appropriate standards and

correctly found that Petitioners were not entitled to

compensation, this Court should deny the Petition.

14

CONCLUSION

For the foregoing reasons, the Petition should be

denied.

Respectfully submitted,

Clayton E. Lovell

Counsel of Record

Duval, Funderburk, Sundbery,

Lovell & Watkins

101 Wilson Avenue

P.O. Box 3017

Houma, LA 70361

(985) 876-6410

Counsel for the Board of Adjustments

and the City of Thibodaux