BROOME V. RIALS:
REDEFINING STATUTORY AND MUNICIPAL BOUNDARIES
Written by Tracey Ford
Almost twenty years have passed since a suburb voted to break away from East Baton Rouge Parish to form an independent city. Recently, however, a petition for municipal incorporation has been thoroughly investigated under Louisiana Revised Statutes § 33:1-7 for the first time. On April 26, 2024, the Louisiana Supreme Court reversed and rendered judgment in favor of the City of St. George’s incorporation, simultaneously establishing a precedent for future communities seeking separation and undermining legislative intent.
This case note examines the Louisiana Supreme Court’s ruling on the municipal incorporation of the City of St. George in Broome v. Rials. First, it discusses the pertinent facts and procedural history that informed the district and appellate court opinions. Second, it provides an overview of the statutory provisions and case law applied by the courts to arrive at their decisions, elaborated upon in the following section. That section addresses the majority’s analysis and interpretation central to its holding. Lastly, this case note explores the potential negative outcomes of diverging from the lower courts’ position.