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Article 2332 on its face requires that the filing be in the
parish of the property’s situs as to immovables and in the parish
or parishes of the spouses’ domicile as to movables. The 1989
filing in St. Tammany Parish complied with the requirements as to
movables in 1989. Although Louisiana law permits a filing of a
marriage contract that applies to some movables but not to
others, the marriage contract involved in the instant case
applied by its terms to all future acquired movables and to the
fruits of all their separate properties. Thus, respondent has
not suggested that any later filings would have been required
under article 2332 merely because of the passage of time or
because the movables relevant to 1994 and 1995 did not exist at
the time of the 1989 St. Tammany Parish filing. See, e.g.,
article 2339, relating to fruits of movables.
The statute does not provide, in terms, that a change in
domicile requires a change in filing situs as to movables, where
there already has been a properly sited filing. Article 2332
does refer to “the parish or parishes in which the spouses are
domiciled.” (Emphasis added.) However, comment (b) to article
2332 suggests that the words “or parishes” merely reflects a
recognition that spouses might be domiciled in separate parishes,
as a result of the repeal of Louisiana law which had provided
that “A married woman has no other domicile than that of her
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