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La. Rev. Stat. § 14:97 (2026)

Simple obstruction of a highway of commerce

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§97. Simple obstruction of a highway of commerce

           A. Simple obstruction of a highway of commerce is either of the following:

           (1) The intentional or criminally negligent placing of anything or the intentional or criminally negligent performance of any act on any railway, railroad, navigable waterway, road, highway, thoroughfare, or runway of an airport, which will render movement thereon more difficult.

           (2) The conspiracy or aiding and abetting of other individuals to commit either the intentional or criminally negligent placing of anything or the intentional or criminally negligent performance of any act on any railway, railroad, navigable waterway, road, highway, thoroughfare, or runway of an airport, which will render movement thereon more difficult.

           B. Whoever commits the crime of simple obstruction of a highway of commerce in a manner that violates the provisions of this Section shall be fined not more than seven hundred fifty dollars or imprisoned for not more than six months, or both.

           C. The provisions of this Section shall not apply to an employee or contractor of any public utility or a provider of electric utility services, communications, telecommunications, video, or information services to the extent that the employee or contractor is acting on behalf of such entity in a road, highway, or thoroughfare.

           Amended by Acts 2014, No. 791, §7, eff. August 1, 2014; Acts 2024, No. 542, §1, eff. August 1, 2024.

Notes of Decisions
Cited in 36 cases (6 in the last 5 years), 1958–2024 · leading case: John Doe v. DeRay Mckesson, 945 F.3d 818 (5th Cir. 2019).
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John Doe v. DeRay Mckesson, 945 F.3d 818 (5th Cir. 2019). · cites it 5× “See La. Rev. Stat. Ann. § 14:97. Indeed, the complaint alleges that Mckesson himself was arrested during the demonstration.”
Discon v. Saray, Inc., 265 So. 2d 765 (La. 1972). · cites it 10× “Plaintiffs urge that the obstruction of navigable waterways is reprobated by R.S. 14:97 [2] and that under this provision, as applied by the Court of Appeal, Fourth Circuit, in D'Albora v.”
Vermilion Corp. v. Vaughn, 356 So. 2d 551 (La. Ct. App. 1978). · cites it 7× “R.S. 14:97 [3] and under 33 U.S.C.A. Sec.”
Mckesson v. Doe, 592 U.S. 1 (2020). “Because Mckesson allegedly directed an unlawful obstruction of a highway, see La. Rev. Stat. Ann. §14:97 (West 2018), the Fifth Circuit held that the First Amendment did not shield him from li- ability for the downstream consequences.”
Nat'l Audubon Soc'y v. White, 302 So. 2d 660 (La. Ct. App. 1975). · cites it 8× “Defendants contend, first, that the McIlhenny Canal is a "public canal," and that plaintiffs have no right to restrict or limit the use of it; and second, that the canal is a "navigable waterway," and that plaintiffs thus are prohibited by LSA-R.S. 14:97 from obstructing or…”
Terrell v. Allgrunn, 114 F.4th 428 (5th Cir. 2024). · cites it 6× “R.S. 14:97. 4 Plaintiffs fail to identify a single genuine dispute of material fact that remains with respect to La.”
D'Albora v. Garcia, 144 So. 2d 911 (La. Ct. App. 1962). · cites it 2× “These acts were alleged to have been committed in violation of LSA-R.S. 14:97 and 38:214. The first of these provides: "Simple obstruction of a highway of commerce is the intentional or criminally negligent placing of anything or performance of any act on any railway, railroad,…”
John Doe v. DeRay Mckesson, 935 F.3d 253 (5th Cir. 2019). “See La. Rev. Stat. Ann. § 14:97. As such, it was patently foreseeable that the Baton Rouge police would be required to respond to the demonstration by clearing the highway and, when necessary, making arrests.”
Day v. Baton Rouge City Police, No. 3:17-cv-00328, 2020 WL 7024478 (M.D. La. Nov. 30, 2020). · cites it 53× “R.S. § 14:97). 17 R. Doc. 30, ¶¶ 87-92 (claim for racially motivated conspiracy).”
Kyle v. City of Bogalusa, 506 So. 2d 719 (La. Ct. App. 1987). “R.S. 14:97 and 48:342. A violation of a traffic regulation is actionable in tort when it is the legal cause of a collision.”
State v. Brister, 514 So. 2d 205 (La. Ct. App. 1987). “Defendant abandoned his challenge to the simple obstruction of a highway (LSA-R.S. 14:97); therefore, we decline to pass on the matter.”
John Doe v. Deray McKesson, 922 F.3d 604 (5th Cir. 2019). “See La. Rev. Stat. Ann. § 14:97. As such, it was patently foreseeable that the Baton Rouge police would be required to respond to the demonstration by clearing the highway and, when necessary, making arrests.”
Show all 36 citing cases →
La. Rev. Stat. § 14:97(A): 1 case
Spoon v. Bayou Bridge Pipeline LLC, 682 F. Supp. 3d 594 (M.D. La. 2023).
La. Rev. Stat. § 14:97(B): 1 case
Henagan v. City of Lafayette, No. 6:21-cv-03946 (W.D. La. Sept. 27, 2022).
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