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Item K2 GROWTH MANAGEMENT LITIGATION REPORT TO: BOCC; Jim Hendrick; Tim McGarry; Jim Roberts FROM: Karen K. Cabanas DATE: July 17, 2002 Vacation Rentals N eumont (Federal Class Action) - Federal class action case alleging vacation rental ordinance was prematurely enforced and is an unconstitutional taking of Plaintiffs' properties. Awaiting ruling on whether the Judge will adopt the Magistrate's recommendation to dismiss all claims under jurisdictional doctrines of abstention and ripeness. If all claims are dismissed, Plaintiffs may appeal to the 11th Circuit federal court or may attempt to file a new cause of action in state court. Those claims should now be barred by the statute oflimitations. ($49,753.75 as of June 30, 2002). Takin2S Claims New Port Largo - State "physical occupation" takings claim that had been remanded back to state court when federal claims were dismissed, Cross-motions for Summary Judgment were heard June 6. The parties have filed additional memoranda of law regarding summary judgment and are awaiting the Court's ruling. The Court has also ordered that mediation be held by the end of July 2002 and trial has been set for September, 2002. ($19,597.00 as of June 30, 2002). Shadek ~ Takings claim for -570 acres of North Key Largo property based on the 1980'5 Major Development Moratorium. Trial was held February 21, 22 and March 13. Judge Garcia ruled in favor of Plaintiffs on all takings claims, declaring Monroe County liable for denying Plaintiffs all economic use of their property for an eight-year period. Petition for Certiorari review was denied by the 3rd District Court of Appeals as a non-final order. Jury trial on damages has been continued, on Plaintiffs' motion, to September 2002. ($162,10224 as of June 30,2002). Tropic Leisure Recreation - Takings claims regarding property on Upper Matecumbe in which Plaintiffs claim they were denied building permits for new construction. Plaintiffs have filed suit against Islamorada and Monroe County sioce permitting requests began prior to incorporation, Plaintiff filed an application for a building permit with Monroe County prior to Village incorporation and eventually received a permit from Islamorada subsequent to incorporation. Monroe County's motion for summary judgment was denied based on existence of disputed material facts. County will pursue establishing those facts through discovery and will likely re-file for summary judgment, ($12,111.50 as of June 30, 2002), Galleon Bay - Petition for Certiorari review ofBOCC's decision to deny vested rights application, Case has been re-assigned to lower keys division, Plaintiffs have also filed a separate action for inverse condemnation. County's motion to dismiss has been filed based 00 available uses other than ~. \ single-family and pending appeal of vested rights denial, ($4,925.00 as of June 30,2002) (does not include prior Galleon Bay matters). Phelps/Hardin - Claim brought in federal court for due process and inverse condemnation based on code enforcement proceedings that resulted in a lien on Plaintiffs' property. Monroe County's motion to dismiss based on Plaintiffs' failure to properly appeal code enforcement orders was denied, Momoe County's answer will be filed by July 18, 2002. ($1,049.00 as of June 30,2002). Gustinger - Case stems from code enforcement prosecution and order imposing lien. Building permits were subsequently issued by Village of Islamorada, Monroe County filed suit to collect monies due under lien. Property owner counter-claimed for declaratory relief and inverse condemnation based on code enforcement proceedings. Plaintiffwas found in violation of various code provision for failure to reconstruct or demoljsh a non-conforming structure damaged by hurricane. Cross-Motions for Summary Judgment were heard May 24. Awaiting ruling. ($10,840,50 as of June 30, 2002). Pontin - Case alleging temporary and permanent taking of property due to allegedly conflicting regulations of County and ACQE/DEP wherein each required the other's prior approval before issuing permits to fill land & plant trees. Monroe County has filed a motion to dismiss based on statute of limitations because Plaintiff was first made aware of the conflicting regulations in 1984 and has also failed to exhaust admini strative remedies, Claims were previously filed and dismissed in 1985 for failure to seek administrative remedies, Defendant Anny Corps of Engineers motion to dismiss was granted. Case has been remanded to state court. ($3,322,50 as of June 30,2002). Moore - (old Marvin's restaurant) - Seeking declaratory relief and takings claims based on County staff's interpretation and application of floodplain regulations. Motion to Dismiss has been filed based on failure to exhaust administrative remedies (Code provides specific procedures for appeaIing such interpretations) and failure to obtain a final decision from the County regarding the application of said regulations through the administrative process. Proposed settlement agreement on this month's agenda. ($3,670.00 as ofJune 30,2002). Good - Seeking declaratory relief and takings claim for -16 acre Sugarloaf Shores property due to commercial moratorium which began January 4, 1996, Monroe County is preparing to file motion for summary judgment. ($4,545.00 as ofJune 30,2002). Industrial Communications & Electronics - Federal district court case alleging denial of due process, equal protection and inverse condemnation based on prior wireless tower moratoria. Monroe County has filed motion to dismiss based on res judicata/collateral estoppel (issue & claim barred by prior court ruling), Plaintiff previously and unsuccessfully challenged moratorium while in effect and should be barred from re-litigating those issues. Oral argument on Monroe County's motion to dismiss was continued by the Court. Awaiting notice of hearing from court, ($3,975.00 as of June 30,2002), 2 Si2ns & Billboards Republic Media/Outdoor Systems - Declaratory action claim filed by billboard owners challenging applicability of Post-Hurricane Emergency Pennitting Policy and the billboard valuation schedule pursuant to code regulations prohibiting repair of non-conforming billboards damaged beyond 50% of their value. No pending motions. See Memorandum sent to T.McGarry regarding legislative amendments to applicable statutes and request for staff to prepare proposed settlement plan. Plaintiffs have moved Court to schedule mediation - hearing set for July 18, ($16,090.00 as of June 30, 2002), Other Matters Taxpayers for Electrification of No Name Key - Declaratory, vested rights, and 91983 claims challenging Monroe County's policy that installing commercial electric service to No Name Key is prohibited by the 2010 comprehensive plan, Proposed settlement agreement was denied by BOCC; case will proceed in litigation, Property owners opposing electrification were granted leave to intervene. Court granted Monroe County's motion for sununary judgment. Plaintiffs have 30 days to appeal to Third DCA ($13,212.00 as oOune 30,2002), Clay (Big Pine Moratorium) - Complaint filed against Monroe County alleging various claims (takings, vested rights, etc.) based on the de facto building moratorium on Big Pine due to the traffic level of service and concurrency mandate, Judgment was entered in favor of Monroe County on basis that concurrency is a state-imposed mandate, not a County regulation; also based on fact that FDOT is responsible for upgrading u.s. 1, not Monroe County and issuance of any building permits by Monroe County may violate state concurrency and Endangered Species Act provisions, Plaintiffs have appealed to 3rd District Court of Appeals. Oral argument was held June 13. Parties are awaiting ruling from 3rd DCA as to whether case has been rendered moot by recent BOee-approval of beneficial use determinations allowing issuance ofpennits, ($15,614,00 as of June 30,2002) Ambrose - Declaratory action claiming vested rights under 9380.05(18) based on filing of subdivision plats. Pursuant to summary judgment proceedings and his previous orders, Judge Payne ordered that Plaintiffs prove ownership of a single Plaintiffs' lot so that legal issues may be appealed rather than spend extensive time in trial court litigating ownership issues as to each lot at issue. Various environmental groups were also granted leave to intervene. Court entered final summary judgment for approximately 75 Plaintiffs. Final Order has been entered by Court and all Defendants have filed notices of appeal. Defendants will likely file a joint brief with the Third DCA The final order is automatically stayed, but Defendants will also seek a stay of any further trial court proceedings (i,e., seeking of judgments for additional Plaintiffs), ($46,621.25 as of June 30,2002), Upper Keys Citizens Association - Two separate cases: (1) Appeal to Div, of Admin. Hearings of Planning Commission's approval of North Key Largo sub-station for Fla. Keys Electric Co-Op. County's brief has been submitted. Oral argument before Third DCA was held June 18 on Petitioner's appeal of the circuit court dismissal of certiorari action. Third DeA has entered its order affinning the trial court's dismissal of the certiorari action, Petitioners' DOAH proceeding will now resume. ($9,510,00 as ofJune 30,2002), 3 Toppino's - Appeal ofBOCC's decision denying re-zoning based on Navy ACQUIl overlay zone prohibiting new development. Re-zoning constitutes "new development" as defined by state growth management act. Florida Keys Citizen's Coalition - DOAH Appeal of Administration Commission's rule change regarding use of "restored permits" for affordable housing, increasing annual residential permitting caps, and allocation of nutrient reduction credits. Parties have entered stipulated abatement of DOAH proceeding pending revision/withdrawal of rule and settlement discussions, Settlement meeting was held with all parties on July 2 (See separate report from Tim McGarry). ($495,00 as of June 30, 2002), Moore (NROGO Appeal) - Appeal of DCA's Final Order approving the County's recently-adopted NROGO regulations. Proposed settlement agreement on this month's agenda, ($2,385.00 as ofJune 30, 2002), 4