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Update: Galleon Bay
Corp. v. Monroe County & State of Florida
January 15, 2008 (Part II).
Judge Audlin, following up on his order throwing out the efforts
of five years of litigation in this case before Circuit Judge Richard Payne,
issued a scheduling order that assumes a bench trial, on liability, in March
2009, seven years after this case was filed! Galleon Bay,
having tossed back a $3 million plus verdict in 2006 -- because of the dishonest
testimony of the County's MAI ("made as instructed") "appraiser," Trent Marr,
during the trial -- will bear this insult with dignity. Ultimately, bad actors
pay the price of their deeds, and Monroe County's exposure in the next
compensation trial will be well over $10 million.
January 15, 2008 (Part I).
Judge Audlin vacated Judge Payne's 2006 Order
Granting Summary Judgment on Liability to Plaintiff (Galleon Bay). Coming
on the heels of his inexplicable order dismissing the 11-Plaintiff Collins
Taking case, we are hard-pressed to understand how a new judge -- with no
experience in regulatory takings law -- can become such an advocate for
confiscatory government behavior.
Click
below for
more details.

Update: State of Florida vs. West &
Richardson
October 30,
2008. Not unexpectedly, the State filed Notices
of Appeal of both the West and Richardson Final Judgments. The
State's Initial Briefs are due 70 days from the Notices of Appeal, or January 8,
2009. Having done about 75 appeals in the past 25 years, I can attest that
nobody ever gets their Briefs in on time -- and the Third DCA is known for its
liberal policy on requests for extensions of time.
October 8,
2008. Judge Garcia entered judgments
totaling $6,877,257 – plus costs and attorneys’ fees – as Just
Compensation for the West and Richardson
parcels. The West heirs were awarded $5,050,000 plus $1,848,114
interest, for the State’s 2004 condemnation of 21 acres (+5.6 acres of submerged
land). Richardson, et al., were awarded $450,000 plus $149,142
interest, for a 4-acre parcel. Yet neither parcel has had any development rights
since 1983, when the County began a series of “rolling” development moratoria in
the Keys. In 1986, the State and County adopted a “one-year” moratorium on
all development on North Key Largo (except Ocean Reef, Anglers’ Club, and
some subdivisions). The 1986 moratorium remains in effect today – over 22 years
after it was imposed.
Judge Garcia agreed with our assertion that these government
acts constitute Condemnation Blight, and ordered the State to appraise the
properties as if no land use regulations had been adopted since 1983. The
Fair Market Values (FMV) of the properties were to be determined as if they
were as buildable today as they were on February 8, 1983.
When the State condemned the parcels in 2004, it had to deposit
“good-faith estimates” of FMV into the registry of the Court. It deposited
$550,000 for West and $80,000 for Richardson. This supports our position that
the State is purchasing Keys’ land at unconscionably low prices. Comparing the
jury verdicts – FMV as of 2004 – to the State’s good-faith deposits, the FMV of
the West parcel was 9.2 times the State’s “good-faith estimate,” or 11 cents on
the dollar. The FMV of the Richardson parcel was 5.6 times the State’s
“good-faith estimate,” or 18 cents on the dollar. Combining the two yields 11-½
cents on the dollar – a ratio of FMV to purchase price of 8.7 to 1.
Keys’ landowners are clearly being snookered by government. To
landowners who have so far resisted the governments’ offers of 10 to 15 cents on
the dollar, we say stand pat; sit tight; do nothing. Ignore their offers. If the
government does not begin condemnation proceedings, you can force the issue by
suing the government for “inverse condemnation.”
If you must say something, say "condemn it"! There are four court
decisions on this website, that describe similar
deceptive tactics by the United States government in the acquisition of
Cape Cod
National Seashore,
Point Reyes
National Seashore,
Assateague
Island National Seashore, and
Voyageurs National
Park. In the Voyageurs National Park scandal, the average FMVs reached by
juries – when compared to the government’s appraisals and offers – averaged 8.85
times the amount the government offered before filing condemnation suits. In
other words, the Government was “offering” only 11.3 cents on the dollar. Sound
familiar?
The difference between the State of Florida's offers for undeveloped
Keys properties, and their real Fair Market Value in condemnation proceedings,
comes down to two words: Condemnation Blight. Owners of such properties -- who
remain unconvinced -- should read Judge Garcia's
Condemnation Blight Order in the West, et
al. case discussed in this post. (This link takes you to my website.)
Landowners should also note that, in eminent domain proceedings
("condemnation"), attorneys fees and costs are paid to their lawyers on top of
what the landowner is awarded by the Court -- which is usually bound by the jury
verdict. There is no downside to an eminent domain proceeding, particularly when
the government takes by a "quick-take" proceeding and has to pay interest on the
jury verdict from the date of the quick-take.
If the government sits on its hands and won't bring a condemnation proceeding,
you can seek out a good inverse condemnation attorney and sue the government.
You may bear some expense in that scenario, and the government may offer to
settle by giving you a building permit. Once the current mortgage panic
subsides, the demand for buildable land
in the Keys should start rising again.
The State has announced its intention to appeal these judgments. If
it does appeal, interest will continue to run on the judgments, and on the
separate costs and attorneys' fee awards, at the rate of 11% per annum. Under
today's financial clouds, that's a pretty good investment. As of
October 26, 2008, no Notice of Appeal had been filed.
June 2,
2008, DEP v. West. The former (as the
State did a "quick-take" in 2004)Landowners filed a Motion for New Trial in this
case, based on information that the jury did not apply the correct law in
reaching its verdict. The State filed a Motion for entry of a "gag order" to
prevent us from revealing this fact on this website or my Blog site. On June 18,
2008, Judge Garcia DENIED the gag order motion.
May
19-22, 2008, DEP v. West.
Finally! The DEP v. West, et al., and
Richardson, et al. , eminent domain trial took place before a 12-person
jury, in Judge Garcia's courtroom on Plantation Key. This 13-year old case did
not get moving until the State converted its "slow-take" (where it could "walk
away" if it didn't like the verdict), to a "quick-take" in 2004. In the
quick-take, the State was required to deposit a "good-faith estimate" of the
properties' value in the registry of the court. It deposited $550,000 for the
West parcel and $80,000 for the Richardson parcel. The jury's verdicts were
$5,060,000 for the West Parcel and $450,000 for the Richardson parcel -- 9.2 and
5.6 times the State's deposits. The State's attorneys vowed to appeal.
April 9, 2007.
The key to this case was Judge Garcia's 23-page Order Granting
Defendants' Motion in Limine on the Issue of Condemnation Blight. To view the
Order,
Click Here.
Click
below for
more details.

Update: Lightner, et al.,
v. Monroe County & State of Florida (BPK-NNK Class Action Taking Suit)
September 26, 2008. We served an
Amended Complaint in the Big Pine Key-No Name Key (Class Action) taking case
on September 26, 2008. You can view the Amended Complaint by clicking
here.
The Amended Complaint includes the following amendments and changes.
1. The major change made in the Amended Complaint was the
addition of two Due Process Counts, one under the United States Constitution and
42 U.S.C. § 1983 (Civil Rights Statute), and a second under the Florida
Constitution, claiming that the Tier system on Big Pine and No Name Keys is
unconstitutional on due process grounds. The two Regulatory Taking claims
(facial and as-applied) in the original Complaint have been consolidated into
one count under the Florida Constitution, and a new Count added to state a claim
under the United States Constitution and 42 U.S.C. § 1983.
2. It adds the State as a Defendant and deletes four
Plaintiffs who are Plaintiffs in other regulatory taking lawsuits against the
Defendants. (We had previously voluntarily dismissed the four.)
3. It deletes the Temporary Taking claim based on the rolling
development moratoria that began in 1992. (We had voluntarily dismissed this
claim previously.)
4. It corrects the numbers of parcels affected by the
near-absolute prohibition on development within Tier I. Instead of
"approximately 1,725" undeveloped Tier I parcels on BPK and NNK, there were
between 1,279 and 1,310 such parcels in private ownership as of July 16, 2008.
(A new GIS data file, that identifies the Tier designation of every parcel,
became available after the Complaint was filed. And over 100 Tier I parcels were
transferred to the State or County since the Complaint was filed.)
March 5, 2007. Judge
Garcia transferred the case to Key West, where it was assigned to Judge Mark
Jones. Its new case number is CA-K-07-280.
February 1, 2007. The County filed a motion to transfer the case from Plantation Key to Key West.
That motion was granted orally on February 13, 2007.
December 18, 2006.
We filed a class action lawsuit
against Monroe County
on behalf of
twelve plaintiffs who own
50 affected properties for payment of just
compensation as required by the Florida and United States Constitutions.
The following
is a summary of the claims against the County.
Update: Groups Two/Three
BUD Challenge
June 24, 2008, 2007 BUD Ordinance Challenge. The Groups Two/Three
challenge to Monroe County's amended Beneficial Use Determination (BUD)
ordinance (Ordinance 35-2007) – with lead Petitioner Sal Gutierrez – was heard
by a DOAH Administrative Law Judge June 24, 2008 in Key West. You can see how the BUD procedure has been
amended since it was initially adopted in 1986, by clicking on the following
links:
1986 BUD
Ordinance –
1996
Comprehensive Plan BUD –
1998 BUD Ordinance –
2007 BUD Ordinance
(Proposed, not yet in effect).
Click here for
the Petition.
Thursday, November 29, 2007.
We filed a
Petition for
Administrative Hearing, on behalf of the Group Two/Three Plaintiffs, challenging
DCA's proposed final order approving Monroe County's proposed revisions to its
Beneficial Use Determination regulations.
Monday, October 1, 2007.
We (that includes the County) attempted to set these BUD
petitions down for hearing the first week in October. Everyone's schedule was so
full that we would have had to hear 24 BUD petitions in 1-1/2 days on October 3
and 4. That seemed impractical so both sides agreed to find a week when they can
all be heard.
February 21, 2007.
I called Tyson Smith and informed him that (a) the BUD
Petitioners would not accept any Monroe County employee as the Hearing Officer
for these applications, and (b) that Mr. Tobin and I are preparing a lawsuit
against the County (and Marathon and Islamorada) seeking a Declaratory Judgment
that their existing land development regulations and comprehensive plans are
confiscatory and unconstitutional on Due Process grounds, because the
Beneficial Use Determination procedure does not lead immediately to an eminent
domain proceeding. The solution, as we see it, is to (a) declare the LDRs and
ComPlans unconstitutional, or (b) order revisions of the BUD provisions to make
the LDRs and ComPlans constitutional.
I suggested to Mr. Smith that scheduling the
23 BUD applications before a County employee/hearing officer would not fly, and
that the County might as well hold off until our BUD lawsuit is filed.
January 25, 2007.
Responding to our November 23rd supplementation of the 2005 BUD
applications, attorney Tyson Smith sent me the following e-mail
message.
"The County
asked that I respond to your letter of November 3, 2006 related to twenty-three
BUD Applications submitted by you. These applications had been returned because
they lacked information necessary for the hearing officers proper determination
under the Comprehensive Plan and the LDRs. In response, you submitted
appraisals for most of the properties, but did not respond to the Countys other
requests."
"While
the County remains of the opinion that the applications lack necessary
information, at your request,
the County will begin reviewing the materials submitted and will schedule
hearings before the hearing officer. However, by doing so, the County does not
waive its right to object, during the BUD proceedings, to any deficiencies in
the materials you have provided."
Click
below for
more details.

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Quick Looks
Last Updated:
January 02, 2009
New Years' Eve:
Collins Watch
Over

Third DCA Reverses Judge
Audlin in Collins and Shands

December 31, 2008
- As I posted on my
blog on New Years' Eve, the Third District
Court of Appeal released 17-page opinions in Collins, et al v. Monroe County &
the State of Florida and
Shands v City of Marathon, a Pacific Legal
Foundation case. These appeals were argued back-to-back on June 30, 2008, in Key
West. Since September, I had been guessing the opinions would be released in
mid-December, and that Chief Judge Gersten would be the author. I was close on
the date, but Circuit Judge Suarez signed the opinions.
Since Circuit Judge Audlin dismissed Collins
and Shands, he has dismissed two more
regulatory taking cases, McCole v City of Marathon &
the State of Florida and Beyer v. City of
Marathon & the State of Florida, on the same grounds (statute of
limitations, ripeness) he invented in Collins
and Shands. In addition, 16th Circuit Judge
Luis Garcia recently dismissed Sutton v. Monroe County,
another regulatory taking case, on equally incorrect statute of limitation
grounds.
Once the usual Motions for Rehearing are concluded in
Collins and Shands, we can expect
the Third District Court of Appeal to remand McCole,
Beyer, and Sutton
in light of the Collins and
Shands decisions.
Group Two Update - There are 25
Beneficial Use Determination (BUD) petitions pending before a State
Administrative Law Judge. These petitions were heard March 18-20, 2008, but no
recommended orders have been issued. One of our major concerns following those
hearings was the County's "position" that it did not have to pay for denying
all, or substantially all, use of land where the owner had not sought
compensation within four years of enactment of the offending regulation. This is
the same argument that Judge Audlin was just reversed on in
Collins and Shands.
Now we can move those BUDs forward and bring 25 more regulatory taking claims in
Circuit Court.
Click on
Collins and/or
Shands to read and/or download the New Years' Eve opinions.
October 30,
2008. Not unexpectedly, the State filed Notices
of Appeal of both the West and Richardson Final Judgments.
Fortunately for the former landowners, these judgments are earning interest at
11% per year until paid.
September 27, 2008.
The Florida Keys Keynoter announced today
that the Monroe County
Administrator was planning to tell the
Florida's "Cabinet" that the solution to the Florida Keys' land acquisition mess
is to get Congress to designate the Keys a National
Park. That, they surmise, would
somehow bring $1.2 billion to the table for buying
all the Tier I and II land in these regulation-abused islands.
See my September 27,
2008, blog entry for additional comment on the National Park nonsense.
September 24, 2008, $46.7 million in Bert Harris
Act claims filed.
Details below.
July 2,
2008. On July 1, 2008, the Supreme Court of
Wisconsin (yes, the über-liberal court that decided
Just v. Marinette County in 1972) ruled
that when a land use district has no "as-of-right" uses, said regulation is
unconstitutional on substantive due process grounds. (Think
Lochner v New York, 198 US 45 (1908).)
Click
here to read the opinion in
Town of Rhine v. Bizzell, et al.,
2008 WI 76 (July 1, 2008).
Sound familiar, Keys landowners? Do I hear "Tier One?"
– "red-flag wetlands?"
– Offshore islands, anyone? It's long past time to start challenging Monroe
County's (and its municipalities') confiscatory land "lack-of-use" regulations,
starting with the bogus "rate-of-development caps," and working our way through
the "tier system" and the local wetland regulations. Oh, and there are no
statutes of limitation on constitutional challenges to ordinances or statutes.
The ordinance in Wisconsin had been in effect over 20 years before Bizzell,
et al., took it down.
July 1, 2008, Collins Oral Argument Review.
Like a good movie, yesterday's oral arguments before Chief Judge Gersten
and District Judges Ramirez and Suarez, went well for the Landowners in
Collins and Shands, and the governments' arguments seemed to fall
flat on their face.
June 24-26, 2008, 2007 BUD Ordinance Challenge. The Groups Two and
Three challenge to Monroe County's amended Beneficial Use Determination (BUD)
ordinance (Ordinance 35-2007) – with lead Petitioner Sal Gutierrez – was heard
by a DOAH Administrative Law Judge June 24th in Key West. You can see how the BUD procedure has been
amended since it was initially adopted in 1986, by clicking on the following
links:
1986 BUD
Ordinance –
1996
Comprehensive Plan BUD –
1998 BUD Ordinance –
2007 BUD Ordinance
(Proposed, not yet in effect).
Click here for
the Petition.
March
18-20, 2008,
Group Two BUD Hearings. The 23 Beneficial Use Determination Petitions
filed October 30, 2005, were heard by Special Master Larry Sartin, a DOAH
Administrative Law Judge,
2.4 years
after the 23 petitions were filed.
SEE BLOG FOR MORE.
There is a lot of similarity between
our Florida Keys cases and other park-building cases across the United
States. Look at these decisions.
1. First is the 1982-2007 North Key Largo
park-building effort, where the State did everything it could to intimidate
people into giving up their property for a fraction of its Fair Market Value.
Click on the following link to read Judge Garcia's April 9, 2007, order in
State of Florida v West.
2. Read a classic
Claims Court decision:
Althaus v. United
States (Voyageurs National Park). The
National Park Service's behavior in this park-building case was
reprehensible, but will sound familiar to Florida Keys landowners. The following
quote from Althaus is from the Nat'l Park Service's version of Acey
Stinson.
I am in charge of acquiring lands for the
National Park Service.
Even though we know what your lands are worth, we are going to try and get them
for 30 cents on every dollar that we feel they are worth. Of course, you
don't have to accept this 30 cents on the dollar. We will let you wait for a
couple of years. If you don't take 30 cents on the dollar right now, you wait
for a couple of years.
After a couple of years if you wont take 30 cents on the dollar, we are going
to condemn it.
We will condemn your property. You know what that is going to mean? That means
that you are going to have to hire an expensive lawyer from the city and he is
going to take one-third of what you get. Plus, you know who is going to have to
pay the court costs. You are. That is in addition to these expensive lawyers.
3. Click on these links to other park-building cases,
where the
government played fast and loose with landowners' rights.
Drakes Bay Land Co. v
United States, (Point Reyes
National Seashore);
Assateague
Island Condemnation; and
US v
Certain Lands in Truro (Cape Cod National Seashore). In all of these cases, you see the same
kinds of intimidation and underhanded tactics that the State of Florida and
Monroe County are using in the Florida Keys (the first example being in
the Florida Keys).
Update: Collins v. Monroe
County & State of Florida
December 31, 2008,
Collins
and
Shands opinions double-reverse Judge Audlin.
Needless to say, we are pleased with the decision of the Third District
Court of Appeal released on New Years' Eve day (at 10:45 AM to be precise). The
Collins opinion is available on this website in pdf format, as is its
companion, Pacific Legal Foundation's
Shands opinion.
June 30, 2008, Collins Oral Argument.
The Collins Oral Argument has been set in
KEY WEST, June 30, 2008, at 9:30 AM (rather than in the Court's Miami
courthouse). The Court of Appeal will also hear a similar regulatory taking
case, Shands v. City of Marathon, dismissed by Judge Audlin in November
2007, immediately following the Collins argument.
June 16, 2008,
Collins Appeal.
The Collins
Reply
Brief was served. In addition to the Reply Brief, the Collins
Landowners filed an Appendix to the Reply Brief, that consisted of two Memoranda
of Law filed in the trial court in 2006:
Plaintiffs' Supp. Memorandum on 4-Year Statute of Limitations, and
Plaintiffs' Supp. Memorandum on 90-Day Statute of Limitation.
April 22,
2008. Monroe County served its
Amended Answer Brief (although it omitted the word "amended" from the title
page).
March 24,
2008. The Court struck the County's Answer Brief.
February 29,
2008. The County's post-Answer Brief motions did not cure
the defects in its brief. The Collins Landowners filed a Motion to Strike
the County's Answer Brief.
January 11,
2008. The State served its
Answer Brief.
The
County's Answer Brief, served a day later, falls short of the Rules of Appellate
Procedure. Apparently the County hopes to cover their lack of record
citations with a late motion to supplement the record.
November 13,
2007. The Collins Landowners served their
Initial Brief. We have asked for some unusual
relief in the Initial Brief.
Monday,
July 2,
2007. Even though it's just wishful thinking on their part, take a look
at Monroe County's
Motion
to Tax Costs and Attorneys' Fees in Collins. Though the Motion won't get it a penny, the
County says it has spent $1,324,618.61
defending this case so far – which it will lose (after a few more
millions of taxpayers' dollars). What on earth do they DO up there in Kansas?
Click below
for more details.

Bert Harris Act Claims
September 24, 2008.
We served 41 Bert Harris Act petitions today on Monroe County and the State of
Florida, seeking $46.7 million in compensation to the owners of 196 Florida Keys
land parcels. Thirty-four claimants' properties are in Tier I, which are
essentially unbuildable. Seven own Tier II property. For Tier I and II
landowners to even compete for a
permit, they would be forced to spend on the order of $235,000 for 20 points
(Tier I) or $117,500 for 10 points (Tier II) just to begin with the same number
of "points" a Tier III landowner starts with.
AND they must acquire all but two of those 10 or 20 points by purchasing their
neighbors' Tier I lots -- at 4 points apiece -- at the bargain basement prices
the government has been paying. I will share with you our appraiser's Fair Market Value analysis that we
provided the County and State in several of the Bert Harris Act petitions. These
are January 1, 2008, "generic" Fair Market Values -- that need to be adjusted if
special conditions exist, such as too little lot area or the need to pay
mitigation in order to place fill in a wetland -- for Upper and Lower Keys
residential lots only.
Lower Keys Lots: Dry $240,000; Canal $320,000; Open Water $520,000
Upper Keys Lots: Dry $170,000; Canal $405,000; Open Water $610,000
Bert Harris Act (BHA) claims. The 1995 Florida Legislature enacted the
Bert Harris Jr., Private Property Rights Protection Act,
now codified at Sec. 70.001, Fla.
Stat. (2008). The BHA allows landowners to demand and receive compensation when a land use regulation
"substantially diminishes" the Fair Market Value of their property.
Under the BHA you must file a claim within
one
year of the effective date of the regulation. We originally believed that the one-year requirement started
to run on Monroe County's "tier system,"
when an ecoterrorist group's administrative challenge to the ordinance that
established the point penalties between the various tiers (and 4 other
ordinances) ended September 26, 2007. However, we had overlooked the
requirement that the County Commission establish, by resolution, the amount of
money an individual would have to pay to purchase either one or two "ROGO
Points." A good argument can be made that the July 16, 2008 resolution (see
below) was the last element of these BHA claims to be put in place. Under that
theory, the one-year statute of limitation for filing a BHA claim does not run
until 1 year after Resolution 218-2008 was adopted (or filed by the Clerk, if
you want to split hairs).
Monroe County did the
homework for you. According to Monroe County Commission Resolution
218-2008, adopted July 16, 2008, a single ROGO point (or two, at most) can now be purchased
from the County for $11,750 each – which is the County's average of 871 lot sales.
Presumably these sales were almost all to government – which would disqualify
all such sales as representing fair market value in an eminent domain proceeding
– but that's a legal argument for another day. Under Ordinance 009-2006, an owner of a Tier I
lot is down 20 points from a Tier III lot. So a Tier I landowner would
have to buy five ROGO lots – at 4 points per lot –
to compete for a permit with Tier III lots, at a cost of
$235,000. Tier 2 and 3A lots are down "only" 10 points, and would have to
purchase 2 lots at 4 points each, and buy 2 points from the County, at a cost of
$117,500.
October
9, 2006.
Six months have passed since the tier system became "effective" on Big Pine and
No Name Keys. It is still too soon to file Bert Harris Act claims for diminution of value of undeveloped
BPK and NNK parcels.
Though the County split the BPK-NNK and "everywhere else" maps
into two ordinances, it adopted one ordinance (No. 009-2006) that establishes
the changes to the ROGO point system that will apply to the new maps. Ordinance
009-2006 is one of the ordinances that was challenged.
The Bert Harris Act does not require a landowner to file a
claim in response to each piece of a confiscatory land use program -- but merely
to file a claim within one year after the whole picture becomes clear. This
picture should become clear if the BOCC approves the "settlement" on October
18th.
July 16, 2006. The tier system
is NOT in
effect. Two local entities challenged the Department of Community Affairs'
orders approving the tier system ordinances. View the documents online,
at
DOAH
Case No. 06-2449GM.
April
1, 2006 --
A "Tier
Map" became effective on
BPK and NNK, but no regulations
came with the map. The
BPK-NNK
Habitat Conservation Plan states that no more than
10 single-family homes will be permitted in Tier
I lands on BPK and
NNK in the next 20 years (0.5
units/year), and only 8 market-rate homes can be built annually on the two
islands. There are currently
1,725
privately-owned, vacant, residential parcels
in Tier I on BPK and NNK.
It is our opinion that these point spreads constitute an unfair
financial burden on individual property owners, that should have been borne by
the public at large, as the purpose of this "system" is to
allow the government to acquire undeveloped, environmentally interesting, land
for free.
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