Iclp19, LLC v. the Unopened Succession of Geraldine Starks

ICLP19, LLC * NO. 2024-CA-0655

VERSUS * COURT OF APPEAL

THE UNOPENED * FOURTH CIRCUIT
SUCCESSION OF GERALDINE
STARKS, ET AL. * STATE OF LOUISIANA

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JCL LOBRANO, J., CONCURS IN THE RESULT

I concur in the result but note concern that the law may inadequately protect

property owners, especially the elderly and impoverished. Starks’s claim, while

falling outside the limited grounds in La. R.S. 47:2286 and not well developed

factually, raises valid questions about pre-sale advertisement requirements. The

2008 reforms did not provide a clear remedy for such violations. The Legislature

should consider whether further clarification is needed to ensure fairness in future

cases.

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