In re Recall of Burnham

448 P.3d 747, 194 Wash. 2d 68
CourtWashington Supreme Court
DecidedSeptember 12, 2019
Docket96839-0
StatusPublished
Cited by5 cases

This text of 448 P.3d 747 (In re Recall of Burnham) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Recall of Burnham, 448 P.3d 747, 194 Wash. 2d 68 (Wash. 2019).

Opinion

This opinion was FIITE IN CLERKS OFFICE filed for record at ^AAon 8UFISUE COURT,81XIE OF VVe^SmieTQN —-

DATS $£P 1 2 Susan L. Carlson Supreme Court Clerk CMEFJUSTICE

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

IN RE THE MATTERS OF THE RECALL OF: No. 96839-0 JEAN BURNHAM,DALE JACOBSON, RYAN SMITH,SUE CAMERON, En Banc

MAYOR AND COUNCIL MEMBERS OF Filed SEP 1 2 2019 THE TOWN OF CATHLAMET.

OWENS,J.- This case concerns a recall petition filed against the mayor and

three members ofthe town council of Cathlamet. All of the charges against the

councillors and most ofthe charges against the mayor pertain to Cathlamet's purchase

of a parcel of real property. The remaining charges against the mayor pertain to his

use of separate town-owned lots to park his personal business vehicles. We hold that

the charges pertaining to Cathlamet's property purchase are legally insufficient

because acquisition of real property is a fundamental government purpose and a

discretionary act that was not manifestly unreasonable in this instance. We hold that

the charges pertaining to the mayor's use of town-owned lots are also legally In re Recall ofBurnham et al., No. 96839-0

insufficient because the mayor's alleged conduct was not substantial. Accordingly,

we affirm the superior court.

FACTS

Cathlamet is a town of550 people on the Columbia River in Wahkiakum County.

In December 2018, Bill WainAvright, a local resident and member of an unincorporated

group called Concerned Citizens of Cathlamet, filed six recall charges against the mayor.

Dale Jacobson, and two identical recall charges each against town council members Jean

Bumham,Sue Cameron, and Ryan Smith. Most ofthe charges pertain to the town's

purchase of a parcel ofreal property located at 20 Butler Street(the Butler Street

Property) in Cathlamet. Charges 1 and 2 against Bumham, Cameron, and Smith, and

charges 1,2, and 3 against Jacobson allege violation ofand conspiracy to violate article

VIII, section 7 ofthe Washington State Constitution via a gift of public fiinds to the

seller ofthe Butler Street Property, Bemadette Goodroe. Charge 4 against Jacobson

alleges on essentially the same basis that he violated RCW 42.23.070(2), which prohibits

municipal officials from giving or receiving gifts related to their official capacities.

The remaining charges against Jacobson pertain to his use of separate town-

owned lots to park personal business vehicles. Charges 5 and 6 against Jacobson allege

violation of article VIII, section 7 ofthe state constitution via a gift of public flinds to

himself and violation ofRCW 42.23.070(1), which prohibits municipal officers from

granting themselves or others "special privileges."

The superior court held a sufficiency hearing regarding the recall charges on In re Recall ofBurnham et al, No. 96839-0

January 22, 2019, and issued a written ruling on January 25, concluding that all charges

were legally insufficient. Wainwright filed a notice of appeal on Februaiy 6.

I. Cathlamefs Purchase ofthe Butler Street Property

The Butler Street Property is a 6,200-square-foot comer lot in Cathlamet. From

the 1920s through the 1970s, it housed a gas station, including four underground fuel

storage tanks. In the 1970s, the town discovered that the tanks were leaking. In 1997,

the Bank ofthe Pacific purchased the Butler Street Property. After soil samples revealed

concentrations of petroleum chemicals exceeding levels permissible by law, the bank

invested in remediating the site. Soil and groundwater samples taken thereafter

demonstrated contamination levels within legal limits. A small quantity of residual

contaminated soil was left in place due to inaccessibility.

An environmental covenant was recorded for the Butler Street Property in 2005 to

prevent disturbance ofthe small area of residual contaminated soil that could not be

removed. The covenant prohibits an owner from undertaking any activity that might

release or expose the residual contaminated soils without prior written approval from the

Department ofEcology(Department). Such activities include digging, piercing the

surface, or placing any objects that stress the surface beyond its load-bearing capacity.

The Department issued a"No Further Action" letter to the bank in 2006, effectively

declaring remediation complete. Clerk's Papers(CP)at 109.

In 2007, Goodroe and her late husband purchased the Butler Street Property from

the bank for $75,000. The bank executed a hold harmless agreement, indemnifying the 3 In re Recall ofBurnham et al, No. 96839-0

Goodroes for any further remediation. The agreement expressly stated that the bank's liability "survive[s] its sale ofthe property ... and shall continue in effect in the event of subsequent sales ofthe property." CP at 120. In 2011,the value ofthe Butler Street

Property was assessed at $75,000; in 2018, it was assessed at $34,400. As of2018, the Butler Street Property was vacant and being used as a parking lot. Sometime prior to

2018, Goodroe served on the town council.

On March 15,2018, Jacobson initiated Cathlamet's purchase ofthe Butler Street

Property from Goodroe and directed the town to convey $1,000 in earnest money.

Goodroe's original asking price was $72,000, which the town negotiated down to

$68,000. Cathlamet hired a private appraiser, who appraised the Butler Street Property

at $40,000, assuming "no lasting environmental impact." CP at 200. The appraisal

noted a likely change in land use to a "possible park/open space." CP at 199. In

declarations, Jacobson and Cameron stated that the council sought to purchase the

Butler Street Property for conversion into a "pocket park." CP at 141, 103. Cameron,

a former environmental health director, declared that the "covenant does not interfere

with any contemplated use ofthe property." CP at 104.

On June 18, the town council held a regular meeting at which the council

approved the purchase ofthe Butler Street Property by a majority vote. In declarations

introduced by Wainwright, two town residents stated that they heard Bumham say in

July 2018 that the council approved the purchase because "'we wanted Bemadette

Goodroe to get her money hack.'" CP at 231, 233. On July 10, Cathlamet's attorney In re Recall ofBurnham et al., No. 96839-0

advised Jacobson against closing on the purchase. The purchase was completed for a

fmal sale price of$68,000. A statutory warranty deed was recorded on July 16.

On December 12, the Department conducted a review ofthe Butler Street

Property and reported that "the requirements ofthe [covenant] have been satisfactorily

completed. No additional remedial action is necessary at this time." CP at 135.

11. Jacobson's Use of Town-Owned Lots To Park His Business Vehicles

Jacobson owns a propane delivery business located across the street from and

adjacent to two vacant lots owned by Cathlamet(not including the Butler Street

Property). Wainwright alleged that beginning in January 2016, Jacobson used the lots to

store, repair, and vent propane delivery trucks without paying compensation to the town.

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Related

In re Recall of Ruelas
565 P.3d 921 (Washington Supreme Court, 2025)
In re Recall of Fortney
503 P.3d 556 (Washington Supreme Court, 2022)
In Re Recall of Snaza
480 P.3d 404 (Washington Supreme Court, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
448 P.3d 747, 194 Wash. 2d 68, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-recall-of-burnham-wash-2019.