A 1982 Shreveport declaration renews forever, and its “residential purposes” clause stopped an Airbnb
A 1982 Shreveport declaration renews forever, and its “residential purposes” clause stopped an Airbnb
2026-09-10 · Louisiana · Courts
What happened. Louisiana's most useful recent authority on short-term rentals in a subdivision came out of Shreveport, and it turned on two words in a forty-three-year-old document.
Marina Homeowners Association, Inc. v. Sean Cahill and Melissa Cahill, No. 56,423-CA, was decided by the Louisiana Court of Appeal, Second Circuit on August 27, 2025 (Cox, J.; before Cox, Marcotte and Ellender, JJ.), on appeal from the First Judicial District Court, Caddo Parish, No. 641,978. The court's own opinion table marks it published. Disposition: affirmed, with costs to the Cahills.
The posture, because it decides how much weight the case carries
This is a merits ruling on two things: de novo review of the denial of the owners' peremptory exception of no right of action, and affirmance of a permanent injunction granted after an evidentiary hearing. It is not a preliminary injunction and it is not a reversal on summary judgment.
Whether rehearing was sought, or a writ application filed with or acted on by the Louisiana Supreme Court, is not established — so nothing here should be read as final.1
The covenants, and the two-word problem
Willow Ridge Subdivision's declaration was recorded September 23, 1982. Article VII, § 1: “No Lot shall be used except for residential purposes.” Article VIII, § 3 set a twenty-year term, then provided that the covenants would be “automatically extended for successive period of ten (10) years” — singular noun, plural adjective — and required a 75 percent membership signature to amend.
The owners argued the singular meant one ten-year extension, which would have expired. The court disagreed:
“Although 'period' is singular, the word 'successive' immediately preceding it indicates that the drafters intended there to be multiple, automatic 10-year periods following the initial 20-year anniversary date.”
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Related Louisiana HOA Topics
- Marina Homeowners Ass’n, Inc. v. Cahill, No. 56,423-CA (La. App. 2 Cir. Aug. 27, 2025) — slip opinion ↩
- Louisiana Court of Appeal, Second Circuit — 2025 opinions index (date, docket, disposition, publication status) ↩
- City of New Orleans — Residential Short Term Rental Owner’s Permit application, attestations page ↩
- Hignell-Stark v. City of New Orleans, No. 24-30160 (5th Cir. Oct. 7, 2025) — published opinion ↩
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