BISHOP PROPERTY MANAGEMENT VS. THE CITY OF JERSEY CITY RENT LEVELING BOARD (L-0602-19, HUDSON COUNTY AND STATEWIDE)

CourtNew Jersey Superior Court Appellate Division
DecidedNovember 9, 2020
DocketA-5516-18T3
StatusUnpublished

This text of BISHOP PROPERTY MANAGEMENT VS. THE CITY OF JERSEY CITY RENT LEVELING BOARD (L-0602-19, HUDSON COUNTY AND STATEWIDE) (BISHOP PROPERTY MANAGEMENT VS. THE CITY OF JERSEY CITY RENT LEVELING BOARD (L-0602-19, HUDSON COUNTY AND STATEWIDE)) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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BISHOP PROPERTY MANAGEMENT VS. THE CITY OF JERSEY CITY RENT LEVELING BOARD (L-0602-19, HUDSON COUNTY AND STATEWIDE), (N.J. Ct. App. 2020).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-5516-18T3

BISHOP PROPERTY MANAGEMENT and MAGNOLIA MANAGEMENT,

Plaintiffs-Appellants,

v.

THE CITY OF JERSEY CITY RENT LEVELING BOARD,

Defendant-Respondent,

and

MARIE CALLE, DANUTA DMOCHOWSKI, GREGORY HODGKINSON, NANCY HOLGUIN, ANDREA JEREZ, HEMAL PATEL, JOSE PINERO, JOSEFINA RESTITUYO, and VITO SERRIPIERRO,

Defendants/Intervenors- Respondents. ___________________________

Submitted September 21, 2020 – Decided November 9, 2020 Before Judges Hoffman, Suter and Smith.

On appeal from the Superior Court of New Jersey, Law Division, Hudson County, Docket No. L-0602-19.

Miller, Meyerson & Corbo, attorneys for appellants (Gerald D. Miller, on the briefs).

Peter J. Baker, Corporation Counsel, attorney for respondent (Cheneise V. Wright, Assistant Corporation Counsel, on the brief).

Gibbons PC, attorneys for intervenors-respondents Danuta Dmochowski, Gregory Hodgkinson, Andrea Jerez, and Vito Serripierro (Lawrence S. Lustberg and Michael R. Noveck, on the joint brief).

Marotta & Garvey, attorneys for intervenors- respondents Marie Calle, Nancy Holguin, Hemal Patel, Jose Pinero, and Josefina Restituyo (Neil D. Marotta, on the joint brief)

PER CURIAM

Plaintiffs Bishop Property Management (Bishop) and Magnolia

Management (Magnolia) appeal from an August 12, 2019 Law Division order

dismissing their complaint in lieu of prerogative writs, which challenged the

decision of the City of Jersey City Rent Leveling Board (the Board) denying

plaintiffs' applications for hardship rental increases. We affirm.

Bishop owns the property at 234 Beacon Avenue, and Magnolia owns the

properties at 27 Concord Street and 3473-3475 Kennedy Boulevard (3475 JFK

A-5516-18T3 2 Blvd), all in Jersey City. Plaintiffs, in order to "maintain [their rental properties]

and make them at least Class B or A rental spaces," between 2017 and 2019,

invested $426,839 in maintenance and repairs for the three rental properties.

Meanwhile, between 2017 and 2018, the city increased the property taxes on

plaintiffs' properties. As a result, the taxes on 234 Beacon Avenue increased

approximately 110 percent, from $17,160 to $36,000; the taxes on 27 Concord

Street increased approximately seventy percent, from $8,190 to $13,912; and

the taxes on 3475 JFK Blvd increased approximately twenty-seven percent, from

$18,041 to $22,700.

Due to the increased tax burden, and the amounts spent on repairs and

maintenance, plaintiffs filed hardship rental increase applications (hardship

applications) with the Board. Bishop filed its hardship application for 234

Beacon Avenue on June 20, 2018, and Magnolia filed its hardship applications

for 27 Concord Street and 3475 JFK Blvd on August 17, 2018 and September

12, 2018, respectively. Plaintiffs' applications sought to increase the maximum

chargeable rent for the properties' units, claiming the latest tax assessment

severely reduced the properties' profitability.

The controlling ordinance for hardship rental increases and plaintiffs'

applications, Jersey City Municipal Code (the Code) §260-10, provides:

A-5516-18T3 3 In the event that a landlord cannot meet his or her mortgage payments or operating expenses or does not make a fair return on his or her investment, he or she may apply to [the Board] for increased rentals, provided that he or she has owned the building for at least nine months prior to the time he or she applies for an increase.

[Emphasis added.]

The Code defines "fair return" as:

The percentage of return on equity of real property investment. The amount of return shall be measured by the net income before depreciation. A "fair return" on the equity investment in real property shall be considered to be 6 [percent] above the maximum passbook demand deposit savings account interest rate available in the municipality.

Further, the Code defines "equity in real property investment" as "[t]he actual

cash contribution of the purchaser at the time of closing of title and any principal

payments to outstanding mortgages subsequent to acquisition of title by the

purchaser." In short, the Code provides that a landlord may apply for a hardship

rental increase when the landlord is not earning a fair return on the equity of his

property investment. Equity of a property investment is measured by the amount

the landlord paid when purchasing the property plus any subsequent mortgage

payments made by the landlord.

A-5516-18T3 4 Despite the Code's language, the hardship application forms provided by

Jersey City's Division of Tenant Landlord Relations indicated landlords could

calculate the equity of their property investment using the purchase price

approach described in the Code or using the property's appraised value. The

application defined equity: "Equity in real property is the owner's down payment

plus payment on the principal. Where the property has been owned for over 10

years the appraised value less outstanding loans may be used to calculate

equity." According to plaintiffs, Jersey City's hardship application forms

included these terms since 1990, and the Board granted applications using the

appraised value approach for nearly thirty years.

In their hardship applications, plaintiffs used the appraised value

approach, rather than the purchase price approach, to calculate the equity of their

properties and to determine the fair return amount they claimed they were

entitled to receive. Plaintiffs calculated the fair return rate at 6.05 percent of the

properties' "net equity," which represented Jersey City's .05 percent passbook

demand deposit interest rate at the time, plus six percent. Plaintiffs listed their

then-existing profits for the three rental properties: 234 Beacon Avenue showed

a $18,072.00 profit; 27 Concord Street showed a $15,355.00 profit; and 3475

JFK Blvd showed a $11,224.00 profit. For 234 Beacon Avenue, based on an

A-5516-18T3 5 appraisal of $2,450,000, Bishop listed a net equity of $2,003,609, which yielded

fair return amount of $121,218. Bishop purchased 234 Beacon Avenue in 1995

for $369,000 with a $500,000 mortgage, of which $446,391 of principal

remained owing. Magnolia listed a net equity of $885,000 based on an appraisal

of that same amount, resulting in a fair return figure of $53,542.50. Magnolia

purchased 27 Concord Street in 1985 for $140,000 without a mortgage. For

3475 JFK Blvd, based on an appraisal of $2,200,000, Magnolia listed a net

equity of $2,050,000, which yielded a fair return amount of $124,025. Magnolia

purchased 3475 JFK Blvd in 1983 for $350,000 taking out a mortgage of

$250,000, of which there remained a balance of $100,000 when the hardship

application was filed.

In accordance with these calculations, plaintiffs requested rent increases

that amounted to an approximate doubling of their tenants' current rent. For

example, the rent of one tenant at 234 Beacon Avenue would have increased

from $800 a month to $1,620 a month. Specifically, for 234 Beacon Avenue,

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BISHOP PROPERTY MANAGEMENT VS. THE CITY OF JERSEY CITY RENT LEVELING BOARD (L-0602-19, HUDSON COUNTY AND STATEWIDE), Counsel Stack Legal Research, https://law.counselstack.com/opinion/bishop-property-management-vs-the-city-of-jersey-city-rent-leveling-board-njsuperctappdiv-2020.