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The State Where the Code Civil Never Left

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The State Where the Code Civil Never Left

This article records tradition as it has been passed down and reported. Its sources are not yet part of the atlas's verified catalogue.

Every other American state traces its private law back to England. Louisiana traces its back to Paris, and to Madrid before that, and the accident of timing is the whole explanation. Louisiana was a Spanish and then a French colonial possession until the United States bought it in 1803, and its settlers had never lived under English common law for a single day before statehood. When the territorial legislature needed a civil code, it did not import one from a common law neighbor. It commissioned two jurists, Louis Moreau-Lislet and James Brown, who in 1808 produced A Digest of the Civil Laws Now in Force in the Territory of Orleans, built on the law already governing the territory. A Louisiana Supreme Court ruling in 1817, Cottin v. Cottin, exposed gaps in that Digest, so in 1822 the legislature commissioned three jurists, Moreau-Lislet again, joined by Edward Livingston and Pierre Derbigny, to revise it properly. Their revision, approved in 1824 and promulgated as the Louisiana Civil Code of 1825, followed the 1804 French Code Civil closely enough that a comparative lawyer can trace articles between the two almost line for line, while keeping Spanish colonial concepts the drafters judged worth preserving. Article 3521 of the new Code did something almost no other code in American history has done: it repealed the entire prior body of Spanish, Roman and French law in one stroke, a deliberate, total break with everything that came before it, rather than the usual codification pattern of tidying existing law into one document. The Code was written in French first and translated into English second, and because the translation carried errors, the French text, not the English one, remained the legally authoritative version for years. None of this makes Louisiana a foreign legal system operating inside American borders. Its criminal law, its constitutional law, its procedure in most courts, all run on the same common law footing as the other forty-nine states, because those bodies of law were never part of what the 1825 Code covered. What survived, and still governs contracts, property, family law and succession in Louisiana today, is specifically the private law inheritance: proof that a legal tradition can outlive the flags that flew over the territory it was written for, so long as the people applying it keep choosing to.

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Sources
The Louisiana Civil Code of 1825 (Louisiana Supreme Court Law Library)
Louisiana Supreme Court Law LibraryLouisiana Supreme Court Law Library research guide, 1825 Civil Code
Quote, Louisiana Supreme Court Law Library research guide, 1825 Civil Code
an all-inclusive piece of legislation meant to break with the past
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