The Descendants Project, Et Al. v. St. John The Baptist Parish, Et Al.

Supreme Court of Louisiana
November 12, 2025
Chief Deputy Clerk of Court
For the Court
The Supreme Court of the State of Louisiana
THE DESCENDANTS PROJECT, ET AL.
VS.
ST. JOHN THE BAPTIST PARISH, ET AL.
No. 2025-C-00543
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I
N RE: Greenfield Louisiana, LLC - Applicant Defendant; Applying For Writ Of
Certiorari, Parish of St. John the Baptist, 40th Judicial District Court Number(s)
77,305, Court of Appeal, Fifth Circuit, Number(s) 24-CA-493;
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November 12, 2025
Writ application granted. See per curiam.
Guidry, J., dissents and assigns reasons.
WJC
JLW
JDH
JBM
PDG
CRC
11/12/2025 "See News Release 050 for any Concurrences and/or Dissents."

SUPREME COURT OF LOUISIANA
No. 2025-C-00543
THE DESCENDANTS PROJECT, ET AL.
VS.
ST. JOHN THE BAPTIST PARISH, ET AL.
On Writ of Certiorari to the Court of Appeal, Fifth Circuit,
Parish of St. John the Baptist
PER CURIAM
Pursuant to the provisions of Article 966(H) of the Louisiana Code of Civil
Procedure, the parties were ordered to file written briefs addressing the question of
whether summary judgment in this matter is appropriate. Now that the parties have
fully briefed the issues before this court, the writ is granted and judgment is rendered
as follows.
At issue in this proceeding is the validity of Ordinance 90-27, adopted in 1990
by the St. John the Baptist Parish Council to change the zoning of certain immovable
property in the parish . Plaintiffs maintain the parish council failed to follow the
proper procedures for amending the proposed ordinance.
Under the parish’s code of ordinances, a change in the parish’s official zoning
map “shall not become effective unless it . . . shall first have been submitted to the
planning commission for review and recommendation.” See St. John Baptist Code
of Ordinances, Section 113 -76. In compliance with this requirement, the original
proposed ordinance was reviewed and unanimously approved by the planning
commission.
The matter then advanced to the parish council . There, the parish’s Home
Rule Charter sets forth detailed procedures for the adoption of an ordinance. See St.

2

John Baptist Par. H.R.C., Art. IV. In relevant part, t he parish council must hold a
public hearing, duly noticed, to consider a proposed ordinance. See St. John Baptist
Par. H.R.C., Art. IV, Sec B(3)( b). At that hearing, “[a]fter all persons have been
given the opportunity to be heard, the council may pass the ordinance with or without
amendments.” See St. John Baptist Par. H.R.C., Art. IV, Sec B(3)(d) (emphasis
added). This amendment authority is subject to the following limitations:
A proposed ordinance shall not be altered or amended during
consideration to nullify its original purpose or to accomplish an object
not consistent with its original purpose.

St. John Baptist Par. H.R.C. Art. IV, Sec B(3)(g).
Using its amendment authority, the parish council amended proposed
Ordinance 90 -27 to require buffer zones between tracts being rezoned to heavy
industrial (I-3) and any adjacent parcels zoned residential (R-1). The buffers would
be zoned industrial (I-1), a more limited subset of I -3, and would be located in the
tracts otherwise being rezoned to I -3. As amended, the ordinance was adopted by
the parish council by a vote of 8-0, with one recusal.
Given these facts, the lower courts erred in finding the amen dment to the
proposed ordinance had to be reviewed by the planning commission. The code of
ordinances requires commission review of a proposed ordinance changing the
zoning map ; however, the code does not address whether the commission must
review a subsequent amendment to the proposed ordinance. Amendments to
proposed ordinances are specifically governed by the Home Rule Charter, which
permits amendments unless they nullify the proposed ordinance’s original purpose
or seek to accomplish an object inconsistent with that purpose. See St. John Baptist
Par. H.R.C. Art. IV, Sec B(3)(g). These limitations ensure the parish council cannot
circumvent the procedural requirements for adopting an ordinance, including one
rezoning property, by making eleventh-hour amendments inconsistent with the
proposed ordinance’s purpose. That did not occur here.

3

For the affected parcels, the planning commission reviewed and unanimously
approved a zoning change from residential and farmland to heavy industrial (I-3).
The parish council’s amendment insert ed a buffer into those parcels t o be zoned
“industrial” (I-1), the most restrictive industrial zoning. While still zoned industrial,
the affected strips were limited to less intensive uses than those already approved by
the commission for the same property. The amendment is consistent with the
original ordinance’s purpose, specifically to change the zoning of the involved
parcels to industrial. See St. John Baptist Par. H.R.C. Art. IV, Sec B(3)(g). Another
review by the planning commission would serve no purpose where the commission
already approved heavier industrial uses for the same property.
For these reasons, the lower courts erred in granting plaintiffs’ motion for
summary judgment and denying the motion for summary judgment filed by
Greenfield Louisiana, LLC. Summary judgment is hereby granted to Greenfield
Louisiana, LLC, dismissing plaintiffs’ claims with prejudice.1
COURT OF APPEAL AND TRIAL COURT JUDGMENTS
REVERSED; SUMMARY JUDGMENT GRANTED TO GREENFIELD
LOUISIANA, LLC.

1 We also find no merit to plaintiffs’ alternative arguments. Their reliance on Louisiana
Revised Statute 33:4726 is misplaced, as that statute expressly applies only to municipalities. As
the trial court pointed out, p laintiffs produced no evidence of fraud by the parish council in the
adoption of Ordinance 90 -27. While plaintiffs maintain the parish zoning maps are conflicting,
they offer no explanation why any such conflicts would invalidate the subject ordinance.
Plaintiffs’ request for oral argument is denied, and their motion to exceed the page limit for the ir
brief’s appendix is granted.