Louisiana Revised Statutes & Codes
La. Rev. Stat. § 32:23 (2026)
Unless specifically made applicable, the provisions of this Chapter shall not apply to persons, teams, motor vehicles and other equipment while actually engaged in work upon a highway, but shall apply to such persons, teams, motor vehicles and other equipment when traveling to or from such work.
✓ current as of May 2026
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§23. Persons and vehicles working on highways; exceptions
Unless specifically made applicable, the provisions of this Chapter shall not apply to persons, teams, motor vehicles and other equipment while actually engaged in work upon a highway, but shall apply to such persons, teams, motor vehicles and other equipment when traveling to or from such work.
Acts 1962, No. 310, §1.
Notes of Decisions
Cited in 5
cases (1 in the last 5 years), 1973–2022 · leading case: Brooks v. State Ex Rel. Dep't of Transp. & Dev., 74 So. 3d 187 (La. 2011).
Brooks v. State Ex Rel. Dep't of Transp. & Dev., 74 So. 3d 187 (La. 2011). “Similarly, La.Rev.Stat. § 32:23 exempts motor vehicles from all restrictions governing their operation on public roads "while actually engaged in work upon a highway," but plaintiff was clearly not engaged in road work.”
Addison v. Travelers Ins. Co., 281 So. 2d 805 (La. Ct. App. 1973). “But defendant, Travelers, contend that the driver of the Highway truck was exempt under the provisions of LSA-R.S. 32:23 which reads as follows: "Unless specifically made applicable, the provisions of the Chapter shall not apply to person, teams, motor vehicles and other…”
Frischhertz Elec. Co. v. State Farm Mut. Auto. Ins., 357 So. 2d 1323 (La. Ct. App. 1978). “In response, plaintiff argues that by R.S. 32:23 the Highway Regulatory Act does not apply to plaintiff’s truck because it was engaged in work on a highway and the municipal ordinance relied upon was not properly introduced into evidence and prevented the court from taking…”
Ivy Dixon v. Louisiana State Police, State of Louisiana, Through the Dep't of Pub. Saf. & Corr., Colonel Kevin W. Reeves, in His Capacity as the Superintendent of Louisiana State Police, & Helen Elizabeth Delatte (La. Ct. App. 2022). “R.S. 32:23(A-C) are met and, thus, the applicable standard of care under the circumstances is ‘reckless disregard.”
Moreau v. Burlington N. Santa Fe, 919 So. 2d 862 (La. Ct. App. 2006). “R.S. 32:23 create a duty upon a municipality to pass ordinances regulating railroad crossings on state highways appears to be res novo, as we have found no case dealing with this contention.”
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