City of Newark, Etc. v. Township of West Milford

CourtNew Jersey Superior Court Appellate Division
DecidedJune 8, 2026
DocketA-3476-23
StatusUnpublished

This text of City of Newark, Etc. v. Township of West Milford (City of Newark, Etc. v. Township of West Milford) 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.

Bluebook
City of Newark, Etc. v. Township of West Milford, (N.J. Ct. App. 2026).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court."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-3476-23

CITY OF NEWARK, DIVISION OF SEWER AND WATER,

Plaintiff-Appellant/ Cross-Respondent,

v.

TOWNSHIP OF WEST MILFORD,

Defendant-Respondent/ Cross-Appellant. _____________________________

Argued May 4, 2026 – Decided June 8, 2026

Before Judges Sabatino and Bergman.

On appeal from the Tax Court of New Jersey, Docket Nos. 6894-2015, 5070-2016, 7402-2018, 8282-2019, 8756-2020, 11966-2020, 03283-2021 and 3338-2021.

Robert D. Blau argued the cause for appellant/cross- respondent (Blau & Blau, attorneys; Robert D. Blau, on the briefs).

Fred C. Semrau argued the cause for respondent/cross- appellant (Dorsey & Semrau, LLC, attorneys; Fred C. Semrau, of counsel; Robert J. Rossmeissl, on the briefs).

PER CURIAM

This appeal arises from a series of tax appeals involving the assessment

of approximately 16,485 acres of watershed property (the "property") owned by

plaintiff City of Newark located in defendant Township of West Milford. The

property was acquired by plaintiff in the early 1900s for the protection of its

water supply and is subject to various legal restrictions, including the Watershed

Protection and Moratorium Act, the Highlands Water Protection and Planning

Act, and, most notably, perpetual conservation easements granted to the New

Jersey Department of Environmental Protection ("NJDEP").

Plaintiff challenged the local property tax assessments for tax years 2014

to 2016 and 2018 to 2021, asserting that the restrictions so severely limit the

utility and marketability of the property as to render it of nominal or no taxable

value. Defendant cross-appealed requesting to increase the assessments,

contending that the property has a higher market value for conservation and

passive recreation purposes. Following a multi-day trial, the tax court affirmed

the assessments, concluding the highest and best use of the property is to hold

or maintain it as open space with public access for passive recreational uses, and

that market evidence, adjusted to account for the conservation easements,

A-3476-23 2 supports the assessments under review. Plaintiff appeals, contending the tax

court erred both in its highest and best use determination and in its valuation

analysis. Defendant seeks affirmance of the Tax Court's judgments from

plaintiff's affirmative appeals and cross-appeals the court's judgment denying its

counterclaim for an increase in the assessments.

After our review of the extensive record, arguments of the parties and

application of the relevant legal principles, we affirm the trial court's judgments

based on the cogent reasons expressed by Judge Joshua D. Novin in his thorough

64-page written opinion.

I.

Plaintiff owns 117 parcels of watershed property containing

approximately 16,485 acres or 24.71 square miles of unimproved land acquired

in the early 1900's to protect its water supply. The subject property is a portion

of 35,000 acres that plaintiff owns across Morris, Passaic, and Sussex counties

for the purpose of protection and preservation of their water supply. 1 It is

heavily forested land, the topography ranges from relatively flat to steep

mountainous slopes, and it includes Echo Lake, Clinton Reservoir, and portions

of Canistear Reservoir.

1 The subject property is a part of the Newark-Pequannock Watershed. A-3476-23 3 The parcels are all zoned R-4 "Very Low Density Residential." Some

permitted uses in R-4 zoning include farms, single-family detached dwelling

units, residential communities that provide central sewer and water facilities,

community residences for the developmentally disabled and community shelters

for victims of domestic violence, equestrian centers, shooting ranges, bed-and-

breakfasts, and wireless telecommunication facilities.

The subject property is restricted by the Watershed Protection and

Moratorium Act, L. 1988, c. 163, as amended by L. 1990, c. 19 (the "Watershed

Protection Act")2 and the New Jersey Highlands Water Protection and Planning

Act, N.J.S.A. 13:20-1 to -35 (the "Highlands Preservation Act").3

Currently, the primary use of the subject property is for passive recreation

that is supported by sale of permits for activities including fishing, boating,

2 The Watershed Protection Act suspended all transfer of watershed properties to allow NJDEP time to establish rules and regulations for the protection of watershed property through the state. The Act is still in effect and prohibits municipalities, municipal utility authorities, and public utilities from conveying any land used to protect public water supply. See In Re Hackensack Water Co., 249 N.J. Super. 164, 172 (App. Div. 1991); N.J.S.A 48:3-7 and N.J.S.A. 48:2- 23.1 3 All major development as defined in the Highlands Protection Act requires approval of the NJDEP. N.J.S.A. 13:20-30(a). A-3476-23 4 hiking, hunting, trapping, and horseback riding. Certain fees are charged for

these activities as follows:

Activity Annual Fee Fishing $30 ($19 for seniors) Hiking $18 Boating $35 Trapping $50 Horseback Riding $39.50 Hunting $50 ($27.50 for seniors) Stream Fishing $7/per day

The average revenue from the sale of the permits for these activities was

$93,052 from the years of 2014-2021, as depicted in this chart:

Year Amount 2014 $101,561 2015 $96,065 2016 $99,654 2017 $86,065 2018 $90,055 2019 $93,308 2020 $114,974 2021 $67,726 Average Per Year: $93,052

A-3476-23 5 The subject property was assessed under the disputed years as follows:

Valuation Total Tax Average Total Implied Implied Date Assessment Ratio of Equalized Equalized Assessed Value Value, Per True Value Acre 10/1/2013 $35,820,050 92.92% $38,549,344 $2,338 10/1/2014 $35,820,050 95.27% $37,598,457 $2,281 10/1/2015 $35,820,050 90.34% $39,650,266 $2,405 10/1/2017 $39,138,250 91.95% $42,564,709 $2,582 10/1/2018 $39,138,250 90.68% $43,160,840 $2,618 10/1/2019 $43,263,400 87.38% $49,511,788 $3,003 10/1/2020 $43,263,400 86.74% $49,877,104 $3,026

Conservation Easements

Between January 2002 and May 2006, for the total consideration of

$27,561,662, plaintiff granted the NJDEP conservation easements on the subject

property. Notable provisions of the conservation easements include:

Purpose. It is the purpose of this Easement to assure that the [subject property] will be retained forever and predominantly in its natural forested condition and to prevent any use of the [subject property] that will impair or interfere with the Conservation Values of the [subject property].

....

A-3476-23 6 Prohibited Acts. Except for those rights expressly reserved, any activity on or use of the [subject property] inconsistent with the purpose of this Easement is prohibited. Without limiting the generality of the foregoing, the following activities and uses are expressly prohibited:

Subdivision and Development. Any new development or subdivision of the [subject property] is expressly prohibited, except for specific rights retained in this Easement.

Structures. Construction of billboards and cellular phone towers, golf courses, airstrips, and helicopter pads are expressly prohibited on the [subject property].

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City of Newark, Etc. v. Township of West Milford, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-newark-etc-v-township-of-west-milford-njsuperctappdiv-2026.