FRIENDS OF RAHWAY BUSINESS, LLC VS. RAHWAY MUNICIPAL COUNCIL AND CITY OF RAHWAY(L-0410-15, UNION COUNTY AND STATEWIDE)

New Jersey Superior Court Appellate Division·Decided July 5, 2017·No. A-1335-15T1·Unpublished

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court."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-1335-15T1

FRIENDS OF RAHWAY BUSINESS, L.L.C.,

Plaintiff-Respondent/ Cross-Appellant,

v.

RAHWAY MUNICIPAL COUNCIL AND CITY OF RAHWAY,

Defendants-Appellants/ Cross-Respondents. _________________________________

Argued May 18, 2017 – Decided July 5, 2017

Before Judges Hoffman, O'Connor and Whipple.

On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. L-0410- 15.

Brian M. Hak argued the cause for appellants (Weiner Lesniak, L.L.P., attorneys; Mr. Hak, of counsel and on the briefs; John P. Miller and Julia O. Donohue, on the briefs).

William H. Michelson argued the cause for respondents.

Robert S. Goldsmith argued the cause for amicus curiae Morristown Partners, Inc., d/b/a Morristown Partnership (Greenbaum, Rowe, Smith & Davis, L.L.P., attorneys; Mr. Goldsmith, of counsel and on the brief; Robert J. Flanagan, III, on the brief).

Edward Purcell argued the cause for amicus curiae New Jersey State League of Municipalities and New Jersey Institute of Local Government Attorneys (Mr. Purcell, Associate Counsel, on the brief).

Edward J. Trawinski argued the cause for amicus curiae New Jersey Managed Districts Association and Ironbound Business Improvement District (Schenck Price Smith & King, L.L.P., attorneys; Mr. Trawinski, on the brief).

Melanie R. Walter, Deputy Attorney General, argued the cause for amicus curiae New Jersey Office of the Attorney General (Christopher S. Porrino, Attorney General, attorney; Melissa H. Raksa, Assistant Attorney General, of counsel; Ms. Walter and Susan M. Scott, Deputy Attorneys General, on the brief).

PER CURIAM

Defendants Rahway Municipal Council and City of Rahway

(Rahway) appeal from the October 19, 2015 Law Division order

invalidating a municipal ordinance enacted under the Special

Improvement District (SID) statutes, N.J.S.A. 40:56-65 to -89.

Plaintiff cross-appealed the denial of counsel fees. Four amicus

briefs were submitted, with the court's approval. Because of the

trial court's misinterpretation of N.J.S.A. 40:56-65 to -89, we

reverse and vacate certain provisions of the October 19, 2015

2 A-1335-15T1 order, affirm the denial of counsel fees, and remand for further

proceedings.

In September 1993, Rahway adopted Ordinance No. A-40-93,

pursuant to N.J.S.A. 40:56-65 to -89, amending the Rahway Municipal

Code to create a SID. The ordinance allowed the city to collect

special assessments on affected properties. In 2014, Rahway

enacted Ordinance No. 0-42-14 (the Ordinance), expanding the SID

to include all non-residential and non-public properties in the

city, and residential properties with more than four units. Rahway

sent letters to affected property owners providing notice of a

December 8, 2014 public hearing. Some affected property owners

claim they only received the notices on December 5, 2014, but at

least twenty-five members of the public attended.

Affected property owners formed plaintiff Friends of Rahway

Business, L.L.C. to challenge the Ordinance, and filed a complaint

in the Law Division through plaintiff. The court conducted a

hearing on October 9, 2015, where plaintiff argued Rahway had not

utilized money from the SID since 1993 and the expansion of the

SID was only to collect additional assessments. Plaintiff also

argued the affected property owners were given insufficient notice

for the Ordinance to be enacted, the scope of the SID was

unprecedented, and defendants' actions amounted to constitutional

violations entitling plaintiff to counsel fees. Rahway asserted

3 A-1335-15T1 all statutory notice requirements were satisfied, and the

Ordinance is subject to a presumption of validity. Rahway

referenced other towns with similar SIDs and argued the statute

does not prohibit a citywide SID.

The judge disagreed with Rahway and invalidated the Ordinance

in the October 19, 2015 order. The judge considered the

legislative intent of the enabling statutes and found the

legislature had not intended for a SID to encompass an entire

city. The judge denied plaintiff counsel fees and failed to

address plaintiff's other arguments. This appeal followed. Amici

support and join in the arguments raised by Rahway, and urge us

to overturn the judge's decision.

At the outset, we note our standard of review. A court may

not substitute its judgment for that of a municipal body unless

it is proven the Board's action was arbitrary, unreasonable or

capricious. Cell S. of N.J., Inc. v. Zoning Bd. of Adjustment of

W. Windsor Twp., 172 N.J. 75, 81 (2002) (citing Medici v. BPR Co.,

107 N.J. 1, 15 (1987)).

Rahway argues the trial judge should have yielded to the

Ordinance's required presumption of validity. Rahway also assails

four findings of the trial judge. Specifically, Rahway challenges

the judge's findings that the SID statute does not allow: 1) a

municipal-wide SID; 2) SIDs containing non-contiguous properties;

4 A-1335-15T1 3) SIDs in an area of a municipality other than a traditional

"downtown" area; and 4) SIDs containing non-commercial use, such

as industrial and certain multi-family apartment properties. We

address each argument in turn.

The judge considered the presumption of validity attached to

municipal ordinances. Lake Valley Assocs., LLC v. Twp. of

Pemberton, 411 N.J. Super. 501, 505 (App. Div.), certif. denied,

202 N.J. 43 (2010). The SID statute provides "municipalities

should be given the broadest possible discretion in establishing

by local ordinance the self-help programs most consistent with

their local needs, goals, and objectives." N.J.S.A. 40:56-

65(b)(3). In fact, the trial judge addressed the presumption by

saying, "[t]his presumption may only be overcome by a showing that

the [O]rdinance is arbitrary or unreasonable, or that it is

constitutionally defective on its face[,]" and "a court need only

decide whether the [O]rdinance represents a reasonable exercise

of the legislature's delegation of authority to municipalities in

enacting the SID statute."

However, the judge determined "[c]ontrary to being

presumptively valid, the court finds [the Ordinance], expanding

the SID, to be irreconcilable with the enabling statutes and the

legislative intent behind the states' enactment." The judge

considered the Ordinance "an improper exercise of the authority

5 A-1335-15T1 delegated to the City Council under the SID statutes," and ordered

it invalidated.

In Fanelli v. City of Trenton, 135 N.J. 582 (1994), our

Supreme Court stated,

In determining whether [an] ordinance is authorized by the SID statute, we do not pass on the wisdom of the City's plan. We need decide only whether the ordinance represents a reasonable exercise of the Legislature's delegation of authority to municipalities in enacting the SID statute. Furthermore, we interpret those delegated powers broadly.

[Fanelli, supra, 135 N.J. at 591 (citations omitted).]

Free access — add to your briefcase to read the full text and ask questions with AI

FRIENDS OF RAHWAY BUSINESS, LLC VS. RAHWAY MUNICIPAL COUNCIL AND CITY OF RAHWAY(L-0410-15, UNION COUNTY AND STATEWIDE), (N.J. Ct. App. 2017).

FRIENDS OF RAHWAY BUSINESS, LLC VS. RAHWAY MUNICIPAL COUNCIL AND CITY OF RAHWAY(L-0410-15, UNION COUNTY AND STATEWIDE) (FRIENDS OF RAHWAY BUSINESS, LLC VS. RAHWAY MUNICIPAL COUNCIL AND CITY OF RAHWAY(L-0410-15, UNION COUNTY AND STATEWIDE)) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Medici v. BPR Co.
526 A.2d 109 (Supreme Court of New Jersey, 1987)
Lehmann v. Toys 'R' US, Inc.
626 A.2d 445 (Supreme Court of New Jersey, 1993)
Grigoletti v. Ortho Pharmaceutical Corp.
570 A.2d 903 (Supreme Court of New Jersey, 1990)
DiProspero v. Penn
874 A.2d 1039 (Supreme Court of New Jersey, 2005)
Fanelli v. City of Trenton
641 A.2d 541 (Supreme Court of New Jersey, 1994)
State v. Gandhi
989 A.2d 256 (Supreme Court of New Jersey, 2010)
Cell South of NJ, Inc. v. ZONING BD. OF ADJUSTMENT OF WEST WINDSOR TWP.
796 A.2d 247 (Supreme Court of New Jersey, 2002)
Bergen Commercial Bank v. Sisler
723 A.2d 944 (Supreme Court of New Jersey, 1999)
LAKE VALLEY ASSO. v. Township
987 A.2d 623 (New Jersey Superior Court App Division, 2010)
2nd Roc-Jersey Associates v. Town of Morristown
731 A.2d 1 (Supreme Court of New Jersey, 1999)
Cherry Hill Manor Associates v. Faugno
861 A.2d 123 (Supreme Court of New Jersey, 2004)
Daniel Tumpson v. James Farina (072813)
95 A.3d 210 (Supreme Court of New Jersey, 2014)
State v. Kelvin Williams (071306)
95 A.3d 721 (Supreme Court of New Jersey, 2014)
State of New Jersey v. Idris R. Perry
110 A.3d 122 (New Jersey Superior Court App Division, 2015)
State v. D.A.
923 A.2d 217 (Supreme Court of New Jersey, 2007)
State v. Munafo
120 A.3d 170 (Supreme Court of New Jersey, 2015)