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Louisiana First Circuit Applies Subsequent Purchaser Doctrine to Property Transfer Involving Closely Held LLC

The Energy Law

In 2009, several of the Bailey family members formed New 90, LLC to manage this and other family-owned property. The defendants moved for summary judgment against New 90, claiming it was barred under the subsequent purchaser doctrine from suing for alleged damage to the property that occurred before New 90 acquired it in 2009.

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Louisiana’s Sabine River Authority Not Entitled To Sovereign Immunity

The Energy Law

To the extent that independent management authority mattered more than commissioner/board member autonomy, the Fifth Circuit found this factor ultimately weighed toward SRA-L being a political subdivision rather than an arm of the state. 2009) (citing McCarthy ex rel. As for the sixth and final factor, though SRA-L pointed to La.

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