Louisiana Revised Statutes & Codes
La. Rev. Stat. § 31:154 (2026)
PART 2. POSSESSION OF LAND AS INCLUDING
✓ current as of May 2026
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PART 2. POSSESSION OF LAND AS INCLUDING
MINERAL RIGHTS
§154. Possession under title as including mineral rights
One who establishes corporeal possession of land as owner under an act translative of title is in possession of the rights in minerals inherent in perfect ownership of land except to the extent mineral rights are reserved in the act or the act is expressly made subject to outstanding mineral rights. This Article does not apply to a mineral lessee of the possessor or any of his ancestors.
Acts 1974, No. 50, §154, eff. Jan. 1, 1975.
Notes of Decisions
Cited in 7
cases (1 in the last 5 years), 1979–2026 · leading case: Smith v. West Virginia Oil & Gas Co., 373 So. 2d 488 (La. 1979).
Smith v. West Virginia Oil & Gas Co., 373 So. 2d 488 (La. 1979). “R.S. 31:154, which indicates that the possession of land as its owner does not constitute possession of the mineral rights inherent in such ownership, insofar as concerns "a mineral lessee of the possessor or any of his ancestors.”
Grace Ranch, LLC v. BP Am. Prod. Co., 252 So. 3d 546 (La. Ct. App. 2018). “R.S. 31:154, "The mineral lease, though it creates a real right in the hands of the lessee is still an elaborate contractual relationship.”
Frank C. Minvielle, L.L.C. v. IMC Global Operations, Inc., 380 F. Supp. 2d 755 (W.D. La. 2004). “R.S. 31:154, “The mineral lease, though it creates a real right in the hands of the lessee is still an elaborate contractual relationship.”
LeSage v. Ellerbee Builders, Inc., 424 So. 2d 282 (La. Ct. App. 1982). “-R.S. 31:154 is dispositive in this case. L.”
Trinidad Petroleum Co. v. Pioneer Nat. Gas Co., 381 So. 2d 808 (La. 1980). “The comment under this article, as the comment under R.S. 31:154 (the Mineral Code), specifically recognizes that the mineral lessor “bound by a mineral lease cannot possess adversely to his lessee”, a primary reason being that the parties both claim under the same chain of…”
Roberts v. Patterson, 108 So. 3d 816 (La. Ct. App. 2013). “R.S. 31:154, the Mineral Code, provides that a possessor of land who goes into possession “under an act translative of title” possesses “the rights in minerals inherent in perfect ownership of the land.”
Vinton Harbor & Terminal Dist. v. Reunion Energy Co. (La. 2026). “R.S. 31:154, 7 cmt. (emphasis added).3 Even accepting a mineral lease’s real right effects for certain purposes, the question presented in this case is who owns the right of action for preacquisition injury to property.”
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