Askew v. City of Kinston

CourtCourt of Appeals of North Carolina
DecidedDecember 29, 2022
Docket22-407
StatusPublished

This text of Askew v. City of Kinston (Askew v. City of Kinston) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Askew v. City of Kinston, (N.C. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2022-NCCOA-900

No. COA22-407

Filed 29 December 2022

Lenoir County, No. 19 CVS 525

JOSEPH ASKEW; CHARLIE GORDON WADE III; and CURTIS WASHINGTON, Plaintiffs,

v.

CITY OF KINSTON, a Municipal Corporation, Defendant.

Appeal by Plaintiffs from order entered 29 September 2021 by Judge Joshua

Willey in Lenoir County Superior Court. Heard in the Court of Appeals 30 November

2022.

Ralph Bryant Law Firm, by Ralph T. Bryant, Jr., for Plaintiffs-Appellants.

Hartzog Law Group LLP, by Dan M. Hartzog, Jr., and Katherine Barber-Jones, for Defendant-Appellee.

COLLINS, Judge.

¶1 Plaintiffs Joseph Askew and Curtis Washington bring this action against

Defendant City of Kinston alleging violations of their constitutional rights to equal

protection and due process resulting from Defendant’s decision to condemn and mark

for demolition three properties in Kinston, North Carolina. Plaintiffs appeal an order

granting Defendant’s motion for summary judgment and dismissing Plaintiffs’ claims ASKEW V. CITY OF KINSTON

Opinion of the Court

with prejudice.1 Because Plaintiffs did not exhaust their administrative remedies

before filing this direct constitutional action in superior court, the trial court lacked

subject matter jurisdiction to hear Plaintiffs’ claims. Accordingly, we vacate the trial

court’s order and remand the matter to the trial court to dismiss Plaintiffs’ claims

without prejudice for lack of subject matter jurisdiction.

I. Factual Background

¶2 Plaintiffs contest Defendant’s decision to condemn and mark for demolition

three properties in Kinston, North Carolina: 110 North Trianon Street and 607 East

Gordon Street, owned by Askew,2 and 610 North Independence Street, owned by

Washington.

A. The Condemnation Process3

¶3 Under N.C. Gen. Stat. § 160A-426, a building inspector has the authority to

declare a building unsafe upon determining that the building is “especially dangerous

1 Plaintiff Charlie Gordon Wade III voluntarily dismissed his complaint without prejudice prior to the order granting summary judgment in favor of Defendant. 2 Askew’s son was the record owner of these properties when they were first

condemned. Ownership was transferred to Askew by deed recorded 24 January 2019. 3 Citing the need for “a coherent organization of statutes that authorize local

government planning and development regulation,” the General Assembly repealed Article 19 of Chapter 160A of the General Statutes and added Chapter 160D in 2019. An Act to Clarify, Consolidate, and Reorganize the Land-Use Regulatory Laws of the State, §§ 2.1.(a), 2.3, 2019 N.C. Sess. Laws 424, 439 (effective 1 Jan 2021). Chapter 160D “collect[s] and organize[s] existing statutes,” and is not intended to “eliminate, diminish, enlarge, [or] expand the authority of local governments . . . .” Id. § 2.1.(e)-(f). Article 19 of Chapter 160A remained in effect at all relevant times in this case. Id. at 547, § 3.2. ASKEW V. CITY OF KINSTON

to life because of its liability to fire or because of bad condition of walls, overloaded

floors, defective construction, decay, unsafe wiring or heating system, inadequate

means of egress, or other causes.” N.C. Gen. Stat. § 160A-426(a). If the owner of a

building that has been condemned as unsafe fails to take prompt corrective action,

the inspector must notify the owner:

(1) That the building or structure is in a condition that appears to meet one or more of the following conditions: a. Constitutes a fire or safety hazard. b. Is dangerous to life, health, or other property. c. Is likely to cause or contribute to blight, disease, vagrancy, or danger to children. d. Has a tendency to attract persons intent on criminal activities or other activities which would constitute a public nuisance. (2) That a hearing will be held before the inspector at a designated place and time, not later than 10 days after the date of the notice, at which time the owner shall be entitled to be heard in person or by counsel and to present arguments and evidence pertaining to the matter; and (3) That following the hearing, the inspector may issue such order to repair, close, vacate, or demolish the building or structure as appears appropriate.

Id. § 160A-428.

If, upon a hearing held pursuant to the notice prescribed in G.S. 160A‑428, the inspector shall find that the building or structure is in a condition that constitutes a fire or safety hazard or renders it dangerous to life, health, or other property, he shall make an order in writing, directed to the owner of such building or structure, requiring the owner to remedy the defective conditions by repairing, closing, ASKEW V. CITY OF KINSTON

vacating, or demolishing the building or structure or taking other necessary steps [within a time period] as the inspector may prescribe . . . .

Id. § 160A-429.

¶4 “Any owner who has received an order under G.S. 160A-429 may appeal from

the order to the city council by giving notice of appeal in writing to the inspector and

to the city clerk within 10 days following issuance of the order.” Id. § 160A-430. “The

city council shall hear and render a decision in an appeal within a reasonable time.

The city council may affirm, modify and affirm, or revoke the order.” Id. “In the

absence of an appeal, the order of the inspector shall be final.” Id.

¶5 N.C. Gen. Stat. § 160A-393, provides for review in the nature of certiorari by

the superior court of the quasi-judicial decisions of decision-making boards under

Chapter 160A, Article 19, which includes the condemnation process and the city

council’s consideration of orders issued pursuant to N.C. Gen. Stat. § 160A-429. See

id. § 160A-393(a)-(b).

¶6 On certiorari review, “the court shall ensure that the rights of petitioners have

not been prejudiced” because the decision being appealed was, inter alia, “[i]n

violation of constitutional provisions,” or “[a]rbitrary or capricious.” Id.

§ 160A-393(k)(1). If the court concludes that the decision was made in error, “then

the court may remand the case with an order that directs the decision-making board

to take whatever action should have been taken had the error not been committed or ASKEW V. CITY OF KINSTON

to take such other action as is necessary to correct the error.” Id. § 160A-393(l)(3).

B. Condemnation of Askew’s Properties

¶7 In 2017, Defendant’s city inspectors generated a list of over 150 properties that

were unoccupied and would be subject to condemnation under North Carolina law.

Inspectors then narrowed the list to 50 properties to prioritize for the condemnation

and demolition process based on the following criteria:

a. Dilapidated, blighted, and/or burned properties; b. Residential (noncommercial) properties; c. Vacant/unoccupied properties; d. Properties in proximity to a public use, such as a school or a park; e. Properties fronting on or in close proximity to a heavily travelled road; f. Properties in proximity to other qualifying properties (ie, forming part of a “cluster” of dilapidated properties); and g. Properties in an area of police concern.

In September 2017, the city council reviewed and approved the inspectors’ criteria

and finalized the list of properties to prioritize for condemnation. The list of 50

properties included 110 North Trianon Street and 607 East Gordon Street.

¶8 110 North Trianon Street was condemned as dangerous to life on 28 November

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Askew v. City of Kinston, Counsel Stack Legal Research, https://law.counselstack.com/opinion/askew-v-city-of-kinston-ncctapp-2022.