Hamlet v. Board of County Commissioners

24 Ohio N.P. (n.s.) 161
CourtClark County Court of Common Pleas
DecidedJune 15, 1922
StatusPublished

This text of 24 Ohio N.P. (n.s.) 161 (Hamlet v. Board of County Commissioners) is published on Counsel Stack Legal Research, covering Clark County Court of Common Pleas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hamlet v. Board of County Commissioners, 24 Ohio N.P. (n.s.) 161 (Ohio Super. Ct. 1922).

Opinion

Geiger, J.

The plaintiffs being joint owners of certain real estate abutting on either side of the roadway leading from New Car-lisle in a southwesterly direction to a point upon the National Pike known as Stringtown, seek a permanent injunction against the board of county commissioners of Clark county, and Leon G. Herrick, Director of the Department of Highways, to prevent the issuing of bonds for the improvement of this stretch of road by the building of a hard surfaced highway.

The proceedings of the board of county commissioners are set out in the petition, and it is alleged that the defendants propose and intend to build, and are taking steps to build, either a re-inforced concrete road at an estimated cost of $45,000, or a bituminous macadam road, at an estimated cost of $40,000, which the plaintiffs allege will not be for the best interests of the public, but on the contrary will be detrimental thereto.

The answers of the State Highway Commissioner and the board of county commissioners are similar, and admit many of the allegations of the petition, and set out the details of the proceedings before the board of county commissioners and the Department of Highways and Public Works under which they seek to proceed to construct the work.

' The answers state that any assessment made upon the lands of the plaintiffs on account of the proposed improvement, will be based on the actual cost of the improvement, and after full notice to the plaintiffs and other affected land owners, of the proposed assessment, and that an opportunity will be given all to oppose the assessment.

It is claimed by plaintiffs, first, that Sections 1204 and 1214, under which the commissioners claim to act, are unconstitutional and contravene the 14th Amendment of the Constitution of the United States, and Article I, Section 1, of the Bill of Rights.

It is further claimed that it would be an abuse of discretion, which the court should enjoin, for the county commissioners to tear up and destroy an already existing highway capable of service fo build up the hard surfaced structure. It is further alleged the county commissioners have not proceeded properly, in the manner which is pointed out more at length.

The plaintiffs assert that Sections 1204 and 1214 are each uri[163]*163constitutional for the reason that they provide for an assess.ment of plaintiff’s property, “without due process of law.”

In the case at bar, there was no petition filed by the abutting property owners, but the action was taken by the commissioners under the provisions of the latter part of Section 1204, providing that they may, without presentation of a petition, make application for state aid for the improvement.

It is urged that if the commissioners acted without a petition, and without notice to the abutting property owners, or those likely to be assessed for the improvement, in the matters which are preliminary to the final assessment, that the assessment ultimately to be made will be made without due process of law.

Counsel cite many cases which it will be impossible to review here in detail, but which have all been examined.

It must be kept in mind, that the money required to pay the assessment is the private property which cannot be taken from the owner without due process of law. The ordering of the improvement of the public highway adjacent to private property, is not in itself the imposition upon that private property of an assessment to pay for the same.

It is urged, however, that Section 1214 provides arbitrarily that 10 per cent, of the cost of the improvement shall be a charge upon the property abutting on the improvement, provided the total amount assessed against any owner of abutting property, shall not exceed 33 per cent, of the value.

It must be conceded that a special assessment to pay for a public improvement cannot exceed the benefits which such improvement is to the property assessed. The fundamental principle underlying an assessment made on property for the cost and expense of a local improvement, is that the property is specially benefited by the improvement beyond the benefits common to the public, and that the assessment of the property to the extent of these benefits violates no constitutional right of the owner, and is just and proper, but it can in no case exceed the benefits without imparing the invioability of private property. Malsh v. Barron, Treas.. 61 O. S., 15.

It is urged that the arbitrary assessment of 10 per cent, of the improvement upon the abutting property owner and the [164]*164permissible assessment of a larger per cent., violates tbe constitutional protection afforded the property owner.

It will, however, be observed, that the statute provides that the assessment shall not exceed 33 per cent, of the valuation of such property for the purpose of taxation, and it must further be clear that such assessment must not violate the constitutional protection that the assessment shall not exceed the special benefits conferred by the improvement. Although the statute states that the minimum assessment of 10 per cent shall be placed upon the abutting property owner, such assessment is further restricted by the statutory provision that it shall not exceed 33 per cent, of the value of the property, and of the constitutional provision that it shall not exceed the special benefits.

The statute must be construed in the light of these further limitations, and if 10 per cent, of the improvement exceeds either 33 per cent, of the value of the property or the amount of the special benefit, to that extent such 10 per cent, must be reduced.

It is, however, urged that the property owners rights are violated because the improvement may be ordered or construction made, without notice to the abutting property owner, and without the right to him to be heard upon the preliminary question.

No right is violated or property taken until the assessment is made upon the property.

Section 1214 provides that the commissioners shall cause the surveyor to make tentative apportionment of the amount to be paid by the owner specially assessed which apportionment shall be made according to the benefits accruing to the land so located. Before this estimate is adopted, notice shall be given by publication, and if any property owner desires to make objection, he may do so, and the commissioners shall hear the same and act as an equalizing board, and may change the assessment, if it is necessary- to make the same just and equitable.

In other words, the statute provides that before the assessment becomes a lein upon the taxed property, an estimate must be made by the county surveyor, according to the benefits, and thereupon the property owner may be heard, and the- commissioners have the power to act upon the same as an equalizing [165]*165board, and they may change the assessment to make the same just and equitable.

Clearly this provides for a hearing before the abutting property owner is actually assessed for the improvement.

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Related

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184 U.S. 61 (Supreme Court, 1902)
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184 U.S. 115 (Supreme Court, 1902)
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184 U.S. 432 (Supreme Court, 1902)
Hibben v. Smith
191 U.S. 310 (Supreme Court, 1903)
Londoner v. City and County of Denver
210 U.S. 373 (Supreme Court, 1908)

Cite This Page — Counsel Stack

Bluebook (online)
24 Ohio N.P. (n.s.) 161, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hamlet-v-board-of-county-commissioners-ohctcomplclark-1922.