United States v. Sid-Mars Restaurant & Lounge, Inc.
2011 U.S. App. LEXIS 12235
5th Cir.2011Background
- Sid-Mar's sued the State of Louisiana in 2006 for just compensation after the Governor commandeered Sid-Mar's land for hurricane/flood protection projects; the United States later began federal condemnation proceedings on portions of the same property in 2009.
- Louisiana commandeered about 10.2 acres (including Sid-Mar's parcel) on Feb 10, 2006 under La. Rev. Stat. 29:721 et seq. to support flood control works, with compensation to owners.
- The Cooperation Agreement contemplated the State's right of entry and the United States’ possible acquisition of property interests, ultimately to be obtained by negotiation or eminent domain.
- A state court action against Louisiana for inverse condemnation was pending when the United States commenced its federal condemnation action on a related parcel in 2009; the United States deposited funds and sought title in federal court.
- The district court stayed the state court proceeding pending resolution of the federal condemnation, prompting Sid-Mar's to appeal the stay.
- The Fifth Circuit affirmed the district court’s stay under Leiter Minerals framework, emphasizing potential conflicts and the need to protect federal jurisdiction in the condemnation action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Anti-Injunction Act applicability | Sid-Mar's argues AIA bars stays against state suits | U.S. conduct of stay authorized under Leiter Minerals | Affirmed stay authority under Leiter Minerals |
| Propriety of stay given facts | State suit predates federal action; no conflict потерня | Stay necessary to protect federal jurisdiction and avoid inconsistent judgments | Stay proper under Leiter Minerals factors |
| Ownership uncertainty and risk of conflict | No flaw in state court determining title vis-à-vis federal taking | Uncertainty about title creation by commandeering necessitates stay | District court properly noted potential conflicts and remand considerations |
Key Cases Cited
- Leiter Minerals, Inc. v. United States, 352 U.S. 220 (1957) (stay valid when needed to protect federal jurisdiction; narrow exception for defensive title quieting)
- Bank of N.Y. & Trust Co. v. United States, 296 U.S. 463 (1936) (prior exclusive jurisdiction doctrine; state court first to possess may keep control of res)
- United States v. Certified Indus., Inc., 361 F.2d 857 (2d Cir.1966) (Leiter Minerals not broad enough to displace prior exclusive jurisdiction; defense/possession distinction)
- Colorado River Water Conservation Dist. v. United States, 424 U.S. 800 (1976) (recognizes limited application of Leiter Minerals under dual-sovereign framework)
- Palmer v. Texas, 212 U.S. 118 (1909) (illustrates the principle of respecting the jurisdiction of the first court to acquire property)