Item O06BOARD OF COUNTY COMMISSION
AGENDA ITEM SUMMARY
Meeting Date: 9/20/06 -MAR Division County Attorney's Of17ce
Bulk Item: Yes X No Staff Contact Person: Suzanne Hutton
AGENDA ITEM WORDING:
Approval to advertise and hold a Public Hearing to be held November 15, 2006 at 3:00 p.m. in Key
Largo, Florida to consider the adoption of a Resolution approving the Proposed Beneficial Use
Determination of Special Master John J. Wolfe In Re: Geneva Sutton Beneficial Use Application,
pursuant to Sec. 9.5-174(a), Monroe County Code.
ITEM BACKGROUND:
Geneva Sutton and her husband purchased two (2) lots located in Key Largo, FL in 1971 with the
expectation of developing either a small condominium development or one or more single-family
residences. The Lots are in the Sparsely Settled (SS) land use district and are vacant. On January 7,
2005, Monroe County receipted an Application for a Determination of Beneficial Use filed on behalf of
Geneva Sutton and payment of $750 (Check #683). Ms. Sutton alleges she "..has been denied all
reasonable economic use of her property by application of Policies 203. L I and 204.2.1 of the Year
2010 Comprehensive Plan (the "Plan') and Sections 9.5-347 and 9.5-348 of the Monroe County Code
(the "Code') and is entitled to relief under Policy 101.18.5 of the Plan and Section 9.5-173 of the
Code. Section 9.5-347 requires a 100% open space ratio for wetlands and 9.5-348 requires a 50 foot
setback from wetlands, which may, in some circumstances, be reduced to 25 feet. " On July 25, 2005, an
evidentiary hearing was held before John J. Wolfe, designated Beneficial Use Special Master for
Monroe County. On July 19, 2006, the Special Master issued a Proposed Beneficial Use Determination
recommending "..that a final beneficial use determination be entered awarding just compensation to
the Applicant to be determined as of 1986 when the Lots became unbuddable by operation of the Plan
and Code." Sec. 9.5-174(a), Monroe County Code, requires the Board approve or reject the Special
Master's determination during a public hearing and that the public be given the opportunity to be heard
and mark arguments for or against the determination during the Board's public hearing.
PREVIOUS RELEVANT BOCC ACTION: NIA
CONTRACT/AGREEMENT CHANGES: N/A
STAFF RECOMMENDATIONS: Approval.
TOTAL COST: N/A BUDGETED: Yes No _
COST TO COUNTY: N/A SOURCE OF FUNDS:
REVENUE PRODUCING: Yes No X AMOUNT PER MONTH Year
APPROVED BY: County Atty _ OMB/Purchasing Risk Management
DIVISION DIRECTOR APPROVAL:
A. HUTTON, COUNTY A TORNEY
DOCUMENTATION: Included X Not Required
DISPOSITION: AGENDA ITEM #
Revised 2/05
LAW OFFICES OF
JOHN J. WOLFE, P.A.
2955 OVERSEAS HIGHWAY
MARATHON, FL 33050
TELEPHONE: (305)743-9858
FACSIMILE: (305)743-7489
July 20, 2006
Julie Thomson
Administrative Assistant
Monroe County Planning Commission
Planning Department
2798 Overseas Highway
Suite 410
Marathon, FL 33050
RE: Beneficial Use Determination — Geneva Sutton
Dear Julie:
Enclosed is the Proposed Beneficial Use Determination for Geneva Sutton.
Very tly o s
John J o e
Wolfe arathonlaw.com
JJW.jd
Cc: Andrew Tobin, Esq.
E. Tyson Smith, Esq.
BENEFICIAL USE
MONROE COUNTY SPECIAL MASTER AUG O r 2w
In Re: Geneva Sutton
Beneficial Use Application
PROPOSED
BENEFICIAL USE DETERMINATION
The application for a beneficial use determination was considered at a duly noticed hearing
on July 25, 2005, before John J. Wolfe, designated Beneficial Use Special Master for Monroe
County. Andrew Tobin represented the Applicant, Geneva Sutton. Tyson Smith represented Monroe
County. Geneva Sutton, Sandra Walters of Sandra Walters Consultants, Inc. and Paul Sutton, the son
of Geneva Sutton testified for the Applicant. Having reviewed and heard all evidence presented,
testimony of witnesses and arguments of counsel, the undersigned Hearing Officer makes the
findings of fact and conclusions of law and proposes the determination as set forth below.
ISSUE
Whether the Applicant has been denied all reasonable economic use of her property by
application of Policies 203.1.1 and 204.2.1 of the Year 2010 Comprehensive Plan (the "Plan"), and
Sections 9.5-347 and 9.5-348 of the Monroe County Code (the "Code"), and whether the Applicant
is entitled to relief under Policy 101.18.5 of the Plan and Section 9.5-173 of the Code. Section 9.5-
347 requires a 100% open space ratio for wetlands. Section 9.5-348 requires a 50 foot setback from
wetlands, which may, in some circumstances, be reduced to 25 feet,
FINDINGS OF FACT
l . The subject property is a portion of Government Lot 1, Section 4, Township 62 East,
Key Largo, Monroe County, Florida, which has not been subdivided. The property has, however,
been described and treated for years as consisting of two parcels, which have been called "Lot 8" and
"Lot 9", and which have been issued separate parcel i.d. numbers by the Monroe County Property
Appraiser. The exact size of the property was not introduced or established at the Hearing, but
according to the testimony and various documents entered into the record, it appears to be 4-5 acres
including the upland and wetland areas. For purposes of this Proposed Determination, and for ease of
reference, the property will be described as the "Lots" with references to the individual parcels, "Lot
8" and "Lot 9" as appropriate. The Lots are in the Sparsely Settled (SS) land use district. The Lots
are vacant.
2. The Applicant (originally with her husband) purchased Lot 8 and one-half of Lot 9 in
1971 for approximately $27,000 and the other half of Lot 9 in 1984 for approximately $60,000-
$64,000. The Applicant purchased the property with the expectation of developing the property with
either a small condominium development or one or more single4amily residences.
3. While not conclusively established by evidence presented at the Hearing, the parties
agreed that The Lots were zoned GU when purchased. Prior to adoption of the 1986 Comprehensive
Plan, a moratorium on "major development" was put into effect around 1983-1984, which prohibited
development on the Lots. This effected the Applicant's ability to develop the Lots after she had
acquired title to the remaining one-half of Lot 9 in 1984. The Lots were subsequently zoned Native
Area (NA), but the Applicant was able to have them rezoned Sparsely Settled (SS) in 1988, which, as
stated above, they remain today. The Applicant had applied for Suburban Residential (SR) zoning,
but that was denied.
4. There was testimony that the Applicant's husband had some type of approval to build
up to 10.3 condominium units in the mid 1970, but that was not acted upon, apparently due to lack of
funds to develop the property. After acquiring the other half of Lot 9, in 1984 and after the
moratorium on major development had ended, the Applicant attempted a number of times from 1989
trough 1997 to determine what she could build on the Lots. The Applicant introduced various items
of correspondence with the County. Two of the items are particularly relevant. The first is an April
25, 1989 letter from Robert Smith, Senior Biologist and Lorenzo Aghemo, Planner, which concludes
that with the SS zoning, the Lots are unbuildable (it goes on to say if the Lots were rezoned SR,
sufficient development rights could be transferred in to build). In 1996, the Applicant applied for a
building permit to construct a single family residence on Lot 8. The application was denied, and the
Applicant appealed to the Monroe County Planning Commission. An April 3, 1997 staffreport to the
Planning Commission prepared by Antonio Gerli and Ralph Gouldy, recommended denial of the
appeal. The report referenced and agreed with the 1989 letter from Smith and Aghemo, and
concluded that the Lots were unbuildable. As will be discussed below, the report concluded that the
buildable area of Lot 8 is only 300 square feet. The report further concludes that even if Lots 8 and 9
are combined, the Lots still are not buildable. Applicant concedes that she has made no further
attempts to obtain building approval or relief since 1997.
5. Several constraints exist that make the Lots unbuildable. The salt marsh and
buttonwood area on the Lots total 10,783 square feet and the hammock area totals 11,841 square
feet. The remainder of the Lots consists of mangrove. As stated above, the open space requirement
for the wetland area is 100%. When all applicable setbacks, including the setback from wetlands
required by Section 9.5-348 are applied, the buildable area is approximately 300 square feet
6. The Applicant, in an attempt to resolve this matter as consistent as possible with both
her goal to construct a single family residence on the Lots and the applicable provisions of the Plan
and Code requirements, and to avoid a takings claim, proposed in her Application for the Beneficial
Use Hearing and at the Hearing, the construction of one single-family residence on the combined
Lots. The proposed house would have a footprint of 2,000 square feet, which is the maximum square
footage allowed to qualify for the reduced 25 foot setback from wetlands pursuant to Section 9.5-
348(d)(7). This would require a 12.5 foot variance from the 25 foot front yard setback requirement.
Side yard setbacks would be met. The house would be located on the least environmentally sensitive
portion of the Lots on the upland area of disturbed hammock. The remainder of the Lots would be
placed under a conservation easement. The proposed location of the house was shown on Attachment
6 to the Application. Development rights. from both Lots would be applied: It was not clear whether
additional development rights would need to be transferred in, but the parties believed that no
transfers of development rights are allowed in the SS zoning district (this was not confirmed).
7. Monroe County appeared at the Hearing only through its counsel. No testimony was
given and no evidence was presented by the County. The County took the position that the
Applicant's right to relief through the beneficial use determination process had expired on statute of
limitations grounds. The County moved to dismiss the proceeding based on this argument. Through a
post -hearing brief requested by the special master, counsel for the County cited a number of cases to
support its position. The County also took the position that, because the Lots were buildable at some
point during the ownership of the property beneficial use was not applicable. The County further
believed that, in any event, the Applicant had not proven that she had been deprived of all economic
value. The County further contended that the Applicant had the burden of showing whether the
offending regulations advanced a legitimate governmental interest. In addition, the County took the
position that the relief requested by the Applicant, a request for a building permit for a single family
residence, was not available to them, because just compensation is the preferred method. Thus, the
County did not respond to the merits of the Applicant's proposed relief other than to say it was not
available.
CONCLUSIONS OF LAW
8. Policy 101.18.5 of the Plan provides that neither the provisions of the Plan, nor the
Land Development Regulations (the "Regulations") shall deprive a property owner of all reasonable
economic use of a parcel of real property which is a lot or parcel of record as of the date of the Plan.
This policy further provides that a property owner may apply for relief from the literal application of
applicable Regulations or of the Plan when such application would have the effect of denying all
economically reasonable use of that property unless such deprivation is shown to be necessary to
prevent a nuisance or to protect the health, safety and welfare of its citizens under Florida Law. All
reasonable economic use is defined as "the minimum use of the property necessary to avoid a taking
within a reasonable period of time as established by current land use case law".
9. Section 9.5-173 of the Code implements the procedure contemplated by Policy
101.18.5 and provides that in order to establish an entitlement to Beneficial Use relief an Applicant
must demonstrate that "the Comprehensive Plan and land development regulations" deprive the
Applicant of all reasonable economic use of the Lot.
10. As is made clear by Policy 101.18.5, the standards applied to determine whether a
regulatory taking has occurred are constitutionally based as set forth in current land use case law.
This subject has been addressed by the U.S. Supreme Court in a number of cases, but there are two
notable cases applicable to the facts presented here. Both cases involved landowners who claimed
that they had been deprived by government regulation of all economically beneficial use of their
property.
In Lucas v. South Carolina Coastal Council, 505 U.S, 1003, 112 S.Ct. 2886, 120 L.Ed. 798
(1992), the property owner had purchased two ocean front lots to build single family homes. Two
years later all development on the lots was prohibited by South Carolina's Beachfront Management
Act. The Court confirmed the standard that when government regulations deny all economically
beneficial or productive use of land, the property owner is entitled to compensation as a taking. In the
Lucas case, clearly all use was prohibited.
In Palazzolo v. Rhode Island, 533 U.S. 606, 121 S.Ct. 2448, 150 L.Ed. 2d 592 (2001), the
property owner had purchased approximately 20 acres of land for development. Many years later,
but prior to development, regulations promulgated by the Rhode Island Coastal Resources
Management Council designated salt marshes of the type on the Palazzolo property as protected
coastal wetlands and significantly limited development. When his development project was turned
down, the property owner sued alleging a taking under the Lucas standard. In that case, a portion of
the land was still developable, which was ascertained to have $200,000 of development value. While
this was significantly less than the development value of the parcel as a whole, the Supreme Court
upheld the Rhode Island Supreme Court's holding that all economically beneficial use was not
deprived. Id at 630.
11. While it may well have been prudent for the Applicant to pursue relief on a more
timely basis, I conclude that the Applicant is not precluded from seeking relief through the County's
beneficial use determination process as a result of the four year statute of limitations cited by the
County. Neither the Code nor the Plan establishes a deadline to apply for such relief. Whether the
Applicant is barred from pursuing a takings claim in court by the statute would be for a court to
decide at that time. I also do not find merit in the argument that because the Lots were buildable at
some time during the ownership by Applicant, that relief would not be appropriate. It was only when
the Lots became unbuildable that a potential claim ripened. I also conclude that the type of relief
requested by the Applicant is not prohibited by the Section 9.5-173. Just compensation is the
preferred option, but is not required. Indeed, Section 9.5-173(a)(2) sets forth the other types ofrelief
which may be appropriate.
12. Applying the standard to the facts presented herein, it has to be concluded that the
inability to construct even one single family residence on the combined Lots under the Plan and
Regulations in effect at the time the Applicant filed the subject Beneficial Use Application would
deny the Applicant all reasonable economic use of the Lot. There is no disagreement that all
development on the Lots is prohibited by the operation of Sections 9.5-347 and 9.5-348, though the
County did not respond to the proposal of the Applicant as a potential way to build in conformance
with the Plan and the Code. Just compensation being the preferred option under the Code is what I
recommend. However, the diminished value of the Lots should be determined as of the time the
offending regulations took effect, which was in 1986. There is no basis for a valuation determined as
of a date almost 20 years later when the Application was made. The County is not prohibited,
however, in any way by Section 9.5-173 from providing relief of the type proposed by the Applicant.
I have recommended just compensation, because, there was no evidence or comment by the County
on the merits of such relief as an alternative.
PROPOSED DETERMINATION .
Based upon the above Findings of Fact and Conclusions of Law, in the absence of any
concurrence by the County with the Applicant's proposal or any similar alternative, I recommend to
the Board of County Commissioners that a final beneficial use determination be entered awarding
just compensation to the Applicant to be determined as of 1986 when the Lots became unbuildable
by operation of the Plan and Code.
DONE AND ORDERED this 19th day of July, 2006