Bonin, et al v. Sabine River Authority, No. 20-40138 (5th Cir. 2023)
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The Sabine River Authority of Louisiana ("SRA-L")was created as a conservation and reclamation district lying within the watershed of the Sabine River, by an act of the Louisiana legislature in 1950. The SRA subsequently entered into a joint venture with the Sabine River Authority, Texas ("SRA-T") to create a dam and reservoir, promote industrial development, and conserve water.
Plaintiffs are Louisiana and Texas property owners who claimed that the SRAs violated their federal Fifth Amendment rights by opening spillway gates to relieve highwater levels in the reservoir during a rain event in March of 2016. Plaintiffs claimed the SRA's actions flooded their properties, causing significant property damage.
The district court determined SRA-L was not an arm of the state and therefore was not entitled to Eleventh Amendment sovereign immunity. SRA-L appealed. Finding that the first Clark factor weighed in favor of sovereign immunity, the Fifth Circuit concluded that the remaining Clark factors weighed against sovereign immunity. Thus, the court held that, under he Eleventh Amendment, the SRA-L is not an "arm of the state."
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