HomeMy WebLinkAboutAMENDED CSURF CENTRE FOR ADVANCED TECHNOLOGY - ODP - MJA110001 - CORRESPONDENCE - CORRESPONDENCE-HEARING (9)Mayor and City Councilmembers
August 31, 2011
Page 6
FCityof
ort Collins
did not abuse its discretion. Therefore, if the Council rescinds its decision and denies the
Grove application, even though there may be competent evidence in the record to support
the Council's decision, I am concerned that the ex parte contact issue could have the
potential to poison the decision and result in the court overturning the Council's new
decision or remanding it back to the Council for further proceedings.
On the other hand, if the Council does rescind its decision, then I believe that the court
would most likely uphold the decision that the Council has already made because there is
ample competent evidence in the record to support that decision.
WPE/pec
Mayor and City Councilmembers
August 31, 2011
Page 5
City of
F6rtColtins
`l�
of the fact that it is not a "site specific development plan" certain rights have been
established by the Council's approval of the plan. (Only final plans are "site specific
development plans" which merit vested property rights status under Colorado law). I
would imagine that the applicant would try, and likely be able to fashion a plausible
claim against the City for a taking, or a property right violation under Section 1983 of the
U.S. Code' if the Council were to overturn its approval based upon the concerns which
have been raised. For example, a winning taking claim was brought against the City of
Monterey, California, in Monterey v. Del Monte Dunes at Monterey, Ltd., where the
United States Supreme Court held that the city effected a regulatory taking or otherwise
injured the developer's property by "unlawful acts" without paying compensation based
upon the fact that the city in a series of repeated rejections denied proposals to develop
the property, each time imposing more rigorous demands on the developer. Although the
facts of this case are quite different, the "unlawful acts" which might be alleged against
the City could most likely pertain to the "ex parte" communications that the appellants
apparently have conducted with the City Councilmembers subsequent to the appeal
decision. As this office has stated many times, ex parte communications in the quasi
judicial setting are not proper. In the context of a quasi judicial setting, the City Council
is acting in a similar manner to that of a judge in a judicial matter. If a judge were to
conduct ex parte communications with a litigant, such communication would constitute a
violation of the judicial code of ethics which would call into question whether the judge
should continue to possess a law license. Such disciplinary remedies are, of course, not
available against the City Council, but these ex parte contacts may expose the City to
liability, even for damages, because of the impropriety of the appellants having contact
with Councilmembers. Certainly the City would defend against such a suit, but it would
be remiss of me not to advise the Council of the risks that could be involved.
More likely than a damage claim would be that either the appellants or the applicant
would file suit in the Larimer County District Court under Rule 106 of the Colorado
Rules of Civil Procedure which authorizes suit against the City if the City has exceeded
its jurisdiction or abused its discretion. The remedies under Rule 106 are that the court
could either uphold or overturn the decision of the City Council or remand the matter to
the City Council for rehearing. I think it would be plausible for the applicant to allege
that the City Council has abused its discretion in entertaining ex parte contacts from the
appellants, as has apparently occurred, if the Council rescinded its decision and came to
the opposite conclusion. Although the Rule 106 proceeding generally will uphold the
decision of the City Council as long as there is any competent evidence in the record to
support the Council's decision, that rule assumes that in making its decision, the Council
` As to the viability of a Section 1983 claim, I am not greatly concerned because such a claim must be founded upon
a showing that a policy or custom existed, that it was attributable to the municipal defendant, that a constitutional
deprivation occurred and that the policy or custom caused the deprivation. I believe that it would be fairly easy for
the City to show that there was not policy or custom of the City or the City Council to engage in ex parte contacts.
In fact, numerous memoranda from this office have established a policy quite to the contrary, Mayor Pro Tern
Ohlson has also read into the record the City's policy regarding ex parte contacts in public City Council meetings as
have others. Therefore, I believe that the greater risk would be the possibility of some type of takings claim under
some theory founded upon the Monterey case mentioned later in this memo.
Mayor and City Councilmembers
August 31, 2011
Page 4
3. The "Floodalain Note"
Fort Collins
There is also an argument made that the floodplain note (which is also referred to as the
secondary use note) prohibits the construction of secondary uses in the floodplain. As
discussed before, the note was not intended to prohibit the construction of secondary uses
in the floodplain, but simply to afford some reasonable development of the property in
the "E" Employment portion of the ODP by allowing what would otherwise be
considered secondary uses to be constructed in the floodplain without counting against
the maximum 25% secondary use limitation.
4. Procedure Moving Forward.
In a nutshell, it does not appear to me that the City Council made a mistake when it
decided the appeal as it did. I believe that the Council's decision regarding the mix of
housing types and the 25% requirement, the FAR note, and the floodplain note (which is
also part of the 25% note) are all supportable and defensible. However, if a majority of
the Council believes that it has made a mistake in deciding this appeal, I believe that the
Council could rescind its decision and start over, either entirely orlimited to certain
issues that have been raised. Under Resolution 2004-112 of the Council pertaining to
rules of procedure governing the conduct of City Council meetings, the Council may
rescind its earlier decision as long as third parties have not taken any action in
detrimental reliance upon that decision. Section 2-48 of the City Code (under the appeals
provisions) provides that any action taken in reliance upon any decision of a board that is
subject to appeal shall be totally at the risk of the person taking such action until all
appeal rights related to such decision have been exhausted, and the City shall not be
liable for any damages arising from any such action taken during said period of time. I
believe that no person could reasonably have taken action in detrimental reliance upon
the Council's decision until all appeal rights, including judicial appeal rights, have been
exhausted. Therefore, the motion to rescind would be safe and appropriate if the Council
believes that it made a mistake. If the Council were to rescind its earlier decision, it
would need to set a date for the hearing to be held on the appeal and ample notice of such
hearing would need to be provided to all parties -in -interest so that procedural due process
is met. The Council would also need to specify the issues to be addressed at the new
hearing. The Council should expect that the applicant will complain that any such new
hearing would fall outside of the 60-day appeal requirement which the applicant believes
to be jurisdictional. I believe that this objection could be overcome as long as ample
notice and a full hearing were held so as to provide adequate procedural due process.
5. Risks.
Beyond the fact that the decision which was made by the City Council is defensible and
reasonable, and, at least to me appears to have been the correct one under the issues that
have been raised, there is another caveat that should be brought to the attention of the
Council if the Council is inclined to rescind its decision and start over. Even though the
Grove development has not yet become manifested as a vested property right by reason
Mayor and City Councilmembers
August 31, 2011
Page 3
Fort Collins
both the ODP requirement must be applied ODP-wide and not to individual project
development plans, and then the "E" Employment district twenty-five percent rule
requirement must also be applied on each individual project development plan,
specifically in defiance of Section 2.3.2(H)(7). Such a bifurcated application of the mix
of uses requirement would seem to result in an execution of law which would be
infeasible and would not be reasonable and just.
Finally, there has been mention made about the "secondary use ODP note". That ODP
note states that the land use breakdown for land in the "E" Employment district within
the ODP shall be 75% primary and 25% secondary with the result that no more than 24.1
acres can be devoted to secondary land uses. The note goes on to say that within the area
located in the 100 year Spring Creek floodplain, any land uses proposed shall not be
considered "secondary" land uses for the purpose of the 25% limitation. As I understand
it from my conversations with Steve Olt, this note was intended to allow for some
reasonable development of the "E" Employment sector of this ODP by carving out an
exception for land uses that are proposed within the floodplain. Steve Olt explained to
me that since primary land uses are not permitted in the floodplain, this exception to the
25% secondary land use rule was established to afford some reasonable use of the
property. It seems to me that based upon the earlier discussion regarding how Section
2.3.2(H)(7) controls over the 25% requirement contained in Section 4.27(D), that the
secondary use ODP note is irrelevant since the secondary use limitations are met under
any circumstance.
2. The "FAR (Floor Area Ratio) Note"
An issue was raised regarding the "FAR Note". The Far Note provides that:
Maximum floor area ratio (building square footage divided by land area
square footage) for all parcels not to exceed .37.
The zone districts in which this ODP is located contain no FAR requirement in the Land
Use Code. The only FAR requirement that can possibly be applied to this ODP is the
FAR requirement contained in Note 5 which establishes a ratio not to exceed .37. That
note also contains a definition of FAR which is to be applied to the .37 limitation. The
definition is "building square footage divided by land area square footage". This
definition is different than the definition that is contained in the Land Use Code for those
zone districts which have established FAR requirements. The definition of the Land Use
Code can not reasonably be applied to the note because- the Land Use Code does not
impose FAR requirements on this ODP. The only reasonable definition to apply to the
note is the definition contained within the note itself. I am advised by Steve Olt that this
ODP complies with the FAR requirement contained in Note 5 as long as the definition
which comes in tandem with the note is used for the calculation. Accordingly, there is no
FAR issue with respect to the ODP.
Mayor and City Councilmembers
August 31, 2011
Page 2
Fort Collins
following permitted uses shall be considered secondary uses in this zone district
[the "E" Employment District] and together shall occupy no more than twenty-
five (25) percent of the total gross area of the development plan ....
(d) residential uses (except mixed -use dwellings when the residential units are
stacked above the primary use which occupies the ground floor).
In its regulation of an Overall Development Plan (ODP), the Land Use Code also provides in
Section 2.3.2(H)(7) that:
Any standards relating to housing density and mix of uses will be applied over the
entire overall development plan, not on each individual project development plan
review. (Emphasis added)
The appellants argue that there is a conflict between Section 2.3.2(H)(7) which pertains
to the standards for the review of ODPs and the zone district standard for the "E"
Employment district contained in Section 4.27(D)(2) which deals with the mix of
secondary uses with other uses in the "E" district. They then argue that Section 1.7.2
which deals with conflicts in the Land Use Code guides the reader to the conclusion that
Section 4.27 trumps Section 2.3.2. I disagree.
Section 1.7.2 of the Land Use Code provides essentially that if there is a conflict the more
specific section controls. If the more specific section cannot be ascertained, then the
more stringent requirement controls. If there were a conflict, which there is not, I believe
that Section 2.3.2 is the more specific section. It states that if there are any standards in
the Land Use Code relating to housing density and mix of uses, those standards will be
applied over the entire ODP, and will not be applied on each individual PDP. The word
"not" in that sentence is operative. I believe that Section 4.27 is a standard relating to
mix of uses and it does pertain to the review of project development plans in the "E"
Employment district. However, Section 2.3.2 controls Section 4.27 as it relates to
"overall development plans". Section 2.3.2 specifically says that those mix of use
standards will be applied over the entire ODP and not to individual project development
plans. I see no conflict.
The question then becomes whether the standard contained in Section 4.27(D)(2) can be
applied over the entire ODP and comply with the Land Use Code. Staff has performed
the analysis and has concluded that the ODP complies. After looking at staff s
calculations, it appears to me that they were done correctly.
It is also a general principle of Colorado law that laws are to be liberally construed in
order that the true intent and meaning of the legislative body may be fully carried out.
(Section 24-212, CRS.) Furthermore, Section 2-4-201, CRS provides that in enacting a
law, the entire law is intended to be effective, a just and reasonable result is intended, a
result feasible of execution is intended and the public interest in favored over any private
interest. In this case, it is hard to imagine how a result would be feasible of execution if
City of
Fort Collins
CONFIDENTIAL
MEMORANDUM
TO: Mayor and City Councilmembers
FROM: W. Paul Eckman, Deputy City Attomeo
THRU: Steve Roy, City Attomey��
DATE: August 31, 2011
City Attorneys Office
300 Laporte Avenue
PO Box 580
Fort Collins, CO 80522
970.221.6520
970.221.6327
fc®ovxom
RE: Reasonableness and Defensibility of the City Council's Decision in the "Grove
Appeal" Pertaining to: (1) the Mix of Housing Uses and the Twenty -Five Percent
Requirement; (2) The "FAR Note'; and (3) The "Floodplain Note".
BOTTOMLINE.
The decision that the City Council made in the "Grove Appeal" is reasonable and defensible
under the terms of the Land Use Code and Colorado law, and can be supported in the event that
the appellants should seek a judicial review of the Council's decision.
If the City Council comes to the conclusion that it has made a mistake in its decision, it could
rescind the decision and schedule a rehearing. However, in doing so, the likelihood is increased
that the applicant might bring legal action against the City either for a taking claim or requesting
the district court in a "Rule 106" hearing to overturn the City Council's new decision or by
requesting the court to remand the matter to the City Council yet again for a third decision.
ANALYSIS:
1. The 25% Requirement.
The Appellants, after the hearing, have communicated through the City Manager regarding some
of the decisions that the City Council made, and principle among those decisions was the
decision that the "Me Grove" complied with the regulations contained in the Land Use Code
pertaining to mix of housing uses, more specifically set forth in Section 4.27(D)(2) which
provides that:
All secondary uses shall be integrated both in function and appearance into a
larger employment district development plan that emphasis primary uses .... the