ULL_Scott
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it's "lower" b/c it's lower down river (ie closer to the gulf)
Not saying its right cause its on the Internet but...
"The Lower Garden District received its name from Samuel Wilson Jr. during a walking tour of the Louisiana Landmarks Society when he was asked by a reporter for its name. Due to its similarity in architecture ot the Garden District and being lower in social scale as well as in architecture, the name seemed to fit perfectly. The new name was officially published in Dixie magazine soon after. Later, in the book published by the Friends of the Cabildo in 1971, Wilson and partners defined what they considered to be the original limits of the District. Other limits have also been defined by the National Register for Historic Districts and the Local Historic District."
history