This note will first briefly discuss the history of hurricane mitigation in New Orleans, the geography of the city, and the Army Corps construction, maintenance, and operation of the MRGO. Second, this note will discuss takings jurisprudence, focusing on the stabilization doctrine and the inverse condemnation principle. In addition, this section will provide a brief overview of St. Bernard Parish v. United States. Third, this note will discuss recovery under the FTCA in the context of In re Katrina Canal Breaches Consol. This case, decided November 18, 2009, held that the Army Corps’ failure to maintain and operate the MRGO properly was a substantial cause for the levee breaches and the subsequent flooding. Fourth, this note will compare In re Katrina Canal Breaches Consol. and St. Bernard Parish v. United States, discussing the issues associated with bringing a claim against the Army Corps for its negligent maintenance and operation of the MRGO. This section will discuss what cause of action is most favorable to the plaintiffs and what plaintiffs should consider before deciding to go forward with a lawsuit.