New Fellowship Baptist Church, located in Delhi, Louisiana, was established in 1919. Florenda and Kathy Beals purchased property located adjacent to the church. The Beals sent the church a notice of trespass warning and told the church it needed to remove its structures and other movable items on its property.
Under La. C.C. art. 3486, a person can acquire property, even without title or possession in good faith, by prescription of 30 years. At trial, multiple witnesses had testified that New Fellowship had had a choir stand in the location for at least 30 years. Other witnesses testified about maintenance services the church had provided and New Fellowship’s indoor plumbing. The trial court ruled in favor of New Fellowship and dismissed the Beals’ trespass claims.
Because whether a party possessed the at-issue property for 30 years without interruption is a factual issue, the appellate court will not reverse the trial court’s finding unless there is manifest error or the trial court abused its discretion.
The appellate court found that the trial court did not make an error in finding that New Fellowship had acquired the disputed property through 30 years of acquisitive prescription. Even though the Beals showed, they had acquired ownership from the prior owners, New Fellowship had possessed the at-issue property for 30 years with the intent to possess it as an owner.
The appellate court pointed to evidence presented at trial about the church’s maintenance on the property and the existence of its sewer line on the at-issue property for over 30 years. Therefore, under La. C.C. 3487, New Fellowship’s prescriptive title superseded the Beals’ title they had obtained from the prior owners.
The appellate court also rejected the Beals’ argument the trial court erred in establishing the boundary line based on New Fellowship’s survey instead of the boundaries provided in the official titles. The appellate court explained that because New Fellowship had proved 30 years of acquisitive prescription, the boundary was fixed based on their possession, not on the boundaries in the title. This broader boundary was appropriate, even though other surveys might have been more accurate because the church had possessed and cared for the additional property beyond that provided in the title. The appellate court agreed with the trial court’s finding New Fellowship had possessed the at-issue property openly, continuously, and without interruption.
Neither the Beals nor the prior owner had interrupted the church’s possession. For example, the church cared for the at-issue property and was never asked to stop doing so. Because the church’s three-window wall, mow line, and indoor plumbing had existed for over 30 years, the trial court did not err in holding the boundary line extended beyond that provided for in the title.
The New Fellowship Baptist Church versus Beals property dispute is a compelling example of the complex legal issues that can arise in boundary conflicts. The case highlights the significance of acquisitive prescription, which allows for property acquisition through uninterrupted possession for a specified period. By demonstrating their continuous use and maintenance of the disputed property for over 30 years, New Fellowship successfully claimed prescriptive title, overriding the Beals’ ownership acquired from previous owners. Furthermore, the court’s ruling on boundary determination emphasized the importance of possession rather than relying solely on the boundaries provided in official titles.
This decision acknowledged the church’s extensive care and possession of the additional property, extending the boundary beyond what was documented in the title. As property disputes often involve intricate legal considerations, this case underscores the importance of seeking professional guidance to navigate the complexities and ensure a fair outcome.
Additional Sources: Florenda Beals and Kathy M. Beals v. New Fellowship Missionary Baptist Church of Delhi, Inc., c/o Daniel L. Dixon
Article Written By Berniard Law Firm
Additional Berniard Law Firm Article on Acquisitive Prescription: How Can I Prove Ownership of Land Through Aquisitive Prescription in Louisiana?