Caitlin Cooley v. Errol G. Williams, in His Official Capacity as Assessor for the Parish of Orleans, 358 So.3d 127

Property at 930 Forstall Street was purchased at an Orleans Parish tax sale by Flag Boy Properties, LLC; Flag Boy recorded an affidavit under La. R.S. 47:2157(D). Flag Boy later sold to Z Squared, which sold to Caitlin Cooley.
Cooley applied for a constitutionally guaranteed homestead exemption; the Orleans Parish Assessor denied the application, concluding Cooley had not acquired valid ownership because prior tax-sale interests were not judicially quieted.
Cooley filed a petition for writ of mandamus asking the district court to compel the Assessor to grant the exemption. The district court denied relief.
Cooley appealed, arguing the assessor’s duty to issue the exemption was ministerial and that the recorded 47:2157(D) affidavit was sufficient to quiet title.
The Fourth Circuit reviewed statutory interpretation de novo and factual findings for manifest error, and affirmed the district court, holding the Assessor acted within his discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Assessor had a ministerial duty to grant Cooley a homestead exemption	Cooley: She qualifies and the assessor must issue the exemption once an applicant shows ownership/qualification	Assessor: Cooley lacks valid ownership; she holds only tax-sale title and no judicial quiet-title exists, so denial was proper	Denied — assessor acted within discretion; mandamus not appropriate because ownership was not established
Whether recording an affidavit under La. R.S. 47:2157(D) alone quiets title	Cooley: The 47:2157(D) affidavit is sufficient to confirm/quiet tax-sale title and thus establishes ownership	Assessor: The D-affidavit evidences notice and may terminate certain pre-sale encumbrances but does not confer full title or replace a judicial quiet-title proceeding	Held: 47:2157(D) affidavit does not by itself vest full ownership; it primarily evidences notice and cancels certain pre-sale impositions/encumbrances, but does not substitute for judicial quieting
Whether writ of mandamus was the proper remedy to compel issuance of exemption	Cooley: Mandamus can compel performance of a ministerial duty (issuance of homestead exemption)	Assessor: Mandamus is extraordinary and not available where discretion or contested ownership exists; judicial proceedings are required to determine title	Held: Mandamus inappropriate; remedy is extraordinary and will not issue where factual/legal discretion exists or title must be judicially resolved

Central Properties v. Fairway Gardenhomes, LLC, 225 So.3d 441 (La. 2017) (reformed tax-sale scheme: tax-sale purchaser obtains tax-sale title/rights that constitute a lien, not immediate full ownership)
Libertas Tax Fund I, LLC v. Laiche, 340 So.3d 236 (La. App. 1 Cir. 2021) (tax-sale purchaser does not acquire full title until judicial quieting or equivalent proceedings are completed)
Flag Boy Props., LLC v. Dickerson, 291 So.3d 241 (La. App. 4 Cir. 2020) (discussed tax-sale affidavit in context of title questions; court noted affidavit’s effect without fully resolving scope)
Hoag v. State, 889 So.2d 1019 (La. 2004) (definition and use of "ministerial duty" in mandamus context)
Robertson v. Stonecreek Builders, LLC, 200 So.3d 851 (La. App. 2 Cir. 2016) (homestead-exemption rules construed strictly against local restrictions)
Humane Soc'y of New Orleans v. Landrieu, 135 So.3d 1195 (La. App. 4 Cir. 2014) (mandamus is extraordinary; not appropriate where discretion or factual determinations are required)
Constr. Diva, L.L.C. v. New Orleans Aviation Bd., 206 So.3d 1029 (La. App. 4 Cir. 2016) (standard of review for denial of mandamus)
Harrah’s Bossier City Inv. Co., LLC v. Bridges, 41 So.3d 438 (La. 2010) (a court’s unargued statements do not create binding precedent)