Louisiana Revised Statutes & Codes

La. Rev. Stat. § 19:2 (2026)

✓ current as of May 2026

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§2. Expropriation by state or certain corporations, limited liability companies, or other legal entities

Notes of Decisions

Cited in 115 cases (2 in the last 5 years), 1953–2021 · leading case: S. Nat. Gas Co. v. Poland, 406 So. 2d 657 (La. Ct. App. 1981).

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S. Nat. Gas Co. v. Poland, 406 So. 2d 657 (La. Ct. App. 1981). · cites it 6× “Compare LRS 48:441 and LRS 19:2 et seq. Obviously in an effort to expedite a Title 19 expropriation, the legislature requires that a defendant file all of his defenses within 15 days after he has been served with notice of the trial date.”

Tennessee Gas Transmission Co. v. Violet Trapping Co., 176 So. 2d 425 (La. 1965). · cites it 8× “This power is inherent in all government, coming into being eo instante with the establishment of the government and continuing as long as the government endures, and does not require recognition by constitutional provision for its existence. Ibid., sec. 1.14, pp. 13-14. It is…”

Louisiana Power & Light Co. v. Caldwell, 360 So. 2d 848 (La. 1978). · cites it 17× “R.S. 19:2 which deals with electric utility companies is the only portion of that statute which requires consideration of the landowner's convenience, the court nevertheless relied on the frequently stated principle that "in the location of rights-of-way considerable discretion…”

ExxonMobil Pipeline Co. v. Union Pac. R.R., 35 So. 3d 192 (La. 2010). · cites it 4× “La. Rev.Stat. § 19:2(8) (emphasis added).”

Humble Pipe Line Co. v. Wm. T. Burton Indus., Inc., 217 So. 2d 188 (La. 1968). · cites it 8× “1 provides that all claims for property by, or for damages to the owner caused by the expropriation of property pursuant to R.S. 19:2 shall be barred by the prescription of two years.”

Gulf States Utils. Co. v. Heck, 191 So. 2d 761 (La. Ct. App. 1966). · cites it 8× “" There is no question but that under the plain meaning of LSA-R.S. 19:2(1) the Gulf States Utilities Company had a right to bring an expropriation suit where a price could not be agreed upon, and it is clear from the record that the price could not *770 be agreed upon.”

Louisiana Power & Light Co. v. Caldwell, 353 So. 2d 1343 (La. Ct. App. 1978). · cites it 7× “We note that of the nine categories under LSA-R.S. 19:2 authorized to expropriate needed property, it is only in category number 7 wherein there is any mention of the convenience of the landowners.”

Gulf & Mississippi River Transp. Co. v. BP Oil Pipeline Co., 730 F.3d 484 (5th Cir. 2013). · cites it 2× “19:2, other than the state or its political corporations or subdivisions, has actually, in good faith believing it had the authority to do so, taken possession of privately owned immovable property of another and constructed facilities upon, under, or over such property with the…”

Louisiana Power & Light Co. v. Caldwell, 353 So. 2d 371 (La. Ct. App. 1978). · cites it 7× “' "We note that of the nine categories under LSA-R.S. 19:2 authorized to expropriate needed property, it is only in category number 7 wherein there is any mention of the convenience of the landowners.”

Sw. Louisiana Elec. Membership Corp. v. Simon, 207 So. 2d 546 (La. Ct. App. 1968). · cites it 6× “19:2) specifically provides that in the case of the transmission of electricity: "The buildings, transmission lines, stations and sub-stations expropriated or for which property was expropriated shall be so located, constructed, operated, and maintained as not to be dangerous to…”

Bd. of Supervisors v. Mid City Holdings, L.L.C., 151 So. 3d 908 (La. Ct. App. 2014). “R.S. 19:2. If such an agreement cannot be reached and all requirements listed in La.”

Calcasieu & S. Ry. Co. v. Witte, 71 So. 2d 854 (La. 1954). · cites it 6× “Since from the evidence it appears that the plaintiff could not possibly have negotiated successfully with the defendant for the right of way, plaintiff claims that this entitles it to bring the suit under the provisions of our statute ([LSA-]R.S. 19:2) and ([LSA-] Civil Code…”

Show all 115 citing cases →

— La. Rev. Stat. § 19:2(1) — 10 cases

Bd. of Com'rs v. Missouri Pac. R. Co., 625 So. 2d 1070 (La. Ct. App. 1993).

Terrebonne Par. Police Jury v. Kelly, 428 So. 2d 1092 (La. Ct. App. 1983).

Terrebonne Par. Police Jury v. Kelly, 472 So. 2d 229 (La. Ct. App. 1985).

Gulf States Utils. Co. v. Heck, 191 So. 2d 761 (La. Ct. App. 1966). “" There is no question but that under the plain meaning of LSA-R.S. 19:2(1) the Gulf States Utilities Company had a right to bring an expropriation suit where a price could not be agreed upon, and it is clear from the record that the price could not *770 be agreed upon.”

State Ex Rel. Dep't of Highways v. Ouachita Par. Sch. Bd., 138 So. 2d 109 (La. 1961).

— La. Rev. Stat. § 19:2(2) — 2 cases

Missouri Pac. RR Co. v. Nicholson, 460 So. 2d 615 (La. Ct. App. 1984).

Illinois Cent. R.R. v. Mayeux, 178 F. Supp. 2d 663 (M.D. La. 2000).

— La. Rev. Stat. § 19:2(5) — 14 cases

S. Nat. Gas Co. v. Poland, 406 So. 2d 657 (La. Ct. App. 1981). “Compare LRS 48:441 and LRS 19:2 et seq. Obviously in an effort to expedite a Title 19 expropriation, the legislature requires that a defendant file all of his defenses within 15 days after he has been served with notice of the trial date.”

Louisiana Resources Co. v. Greene, 406 So. 2d 1360 (La. Ct. App. 1981).

S. Nat. Gas Co. v. Poland, 384 So. 2d 528 (La. Ct. App. 1980).

USG PIPELINE v. 1.74 Acres in Marion Cnty., Tenn., 1 F. Supp. 2d 816 (E.D. Tenn. 1998).

Acadian Gas Pipeline Sys. v. Bourgeois, 890 So. 2d 634 (La. Ct. App. 2004).

— La. Rev. Stat. § 19:2(6) — 1 case

Sw. Elec. Power Co. v. Conger, 280 So. 2d 254 (La. Ct. App. 1973).

— La. Rev. Stat. § 19:2(7) — 19 cases

Louisiana Power & Light Co. v. Caldwell, 360 So. 2d 848 (La. 1978). “R.S. 19:2 which deals with electric utility companies is the only portion of that statute which requires consideration of the landowner's convenience, the court nevertheless relied on the frequently stated principle that "in the location of rights-of-way considerable discretion…”

Louisiana Power & Light Co. v. Caldwell, 353 So. 2d 1343 (La. Ct. App. 1978). “We note that of the nine categories under LSA-R.S. 19:2 authorized to expropriate needed property, it is only in category number 7 wherein there is any mention of the convenience of the landowners.”

Louisiana Power & Light Co. v. Caldwell, 353 So. 2d 371 (La. Ct. App. 1978). “' "We note that of the nine categories under LSA-R.S. 19:2 authorized to expropriate needed property, it is only in category number 7 wherein there is any mention of the convenience of the landowners.”

Columbia Gulf Transmission Co. v. Hoyt, 215 So. 2d 114 (La. 1968).

Claiborne Elec. Co-op., Inc. v. Garrett, 357 So. 2d 1251 (La. Ct. App. 1978).

— La. Rev. Stat. § 19:2(8) — 6 cases

ExxonMobil Pipeline Co. v. Union Pac. R.R., 35 So. 3d 192 (La. 2010). “La. Rev.Stat. § 19:2(8) (emphasis added).”

Exxon Pipeline Co. v. Hill, 788 So. 2d 1154 (La. 2001).

Gulf & Mississippi River Transp. Co. v. BP Oil Pipeline Co., 730 F.3d 484 (5th Cir. 2013). “19:2, other than the state or its political corporations or subdivisions, has actually, in good faith believing it had the authority to do so, taken possession of privately owned immovable property of another and constructed facilities upon, under, or over such property with the…”

Exxon Pipeline Co. v. Hill, 763 So. 2d 144 (La. Ct. App. 2000).

Pipeline Tech. Vi, LLC v. Ristroph, 991 So. 2d 1 (La. Ct. App. 2008).

— La. Rev. Stat. § 19:2(9) — 14 cases

Louisiana Power & Light Co. v. City of Houma, 229 So. 2d 202 (La. Ct. App. 1969).

Sw. Louisiana Elec. Membership Corp. v. Simon, 207 So. 2d 546 (La. Ct. App. 1968). “19:2) specifically provides that in the case of the transmission of electricity: "The buildings, transmission lines, stations and sub-stations expropriated or for which property was expropriated shall be so located, constructed, operated, and maintained as not to be dangerous to…”

Cent. La. El. Co. v. Covington & St. Tammany L. & I. Co., 131 So. 2d 369 (La. Ct. App. 1961).

Dixie Elec. Membership Corp. v. Watts, 268 So. 2d 128 (La. Ct. App. 1972).

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