In the Matter of the Application of the Borough of Emerson, Etc.

CourtNew Jersey Superior Court Appellate Division
DecidedSeptember 5, 2025
DocketA-0238-23
StatusUnpublished

This text of In the Matter of the Application of the Borough of Emerson, Etc. (In the Matter of the Application of the Borough of Emerson, Etc.) 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
In the Matter of the Application of the Borough of Emerson, Etc., (N.J. Ct. App. 2025).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-0238-23

IN THE MATTER OF THE APPLICATION OF THE BOROUGH OF EMERSON, BERGEN COUNTY, NEW JERSEY, FOR A DECLARATORY JUDGMENT. ________________________________

Argued April 1, 2025 – Decided September 5, 2025

Before Judges Gooden Brown and Smith.

On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Docket No. L-6300-15.

Jason M. Pfeffer argued the cause for appellant Emerson Redevelopers Urban Renewal, LLC (Sills, Cummis & Gross, PC, attorneys; Joseph B. Fiorenzo, of counsel and on the briefs; Stephen M. Klein, on the briefs).

Brian T. Giblin, Jr., argued the cause for respondent Borough of Emerson (Giblin & Gannaio, attorneys; Brian T. Giblin, Sr., and Brian T. Giblin, Jr., on the brief).

PER CURIAM This appeal arises out of the efforts of the Borough of Emerson (Borough)

to comply with its third round of affordable housing obligations and the

contentions of appellant Emerson Redevelopers Urban Renewal, LLC (ERUR)

that the Borough failed to meet its obligations. In seeking a declaratory

judgment that it had a compliant affordable housing plan, the Borough entered

into a settlement agreement with the Fair Share Housing Center (FSHC). The

settlement agreement described the Borough's fair share plan and detailed

several projects the Borough was undertaking to meet its affordable housing

obligations, including ERUR's project to redevelop Block 419 in the Borough's

central business district (CBD) zones. The Block 419 project was a mixed-use

development containing twenty-nine affordable housing units, seven of which

ERUR had the option to locate off-site at another location in the Borough or

make a payment in lieu of construction. The trial judge entered a conditional

final judgment of compliance and repose, accepting the settlement agreement

which included the Borough's fair share plan and finding the plan provided a

realistic opportunity for affordable housing.

Subsequently, ERUR purchased another property in the Borough's CBD

zones and opted to build the seven off-site units from the Block 419 project at

that site. When ERUR applied to the Borough's Land Use Board (Board) to

A-0238-23 2 build a seven-unit affordable housing project at the new location, the Board

declined to proceed because the proposed project at the new location required a

use variance, which, in the CBD zones, could only be accomplished through an

amendment to the Borough's redevelopment plan. ERUR filed a motion in

aid of litigant's rights pursuant to Rule 1:10-3, seeking an order to compel the

Borough to grant site plan approval for its new location without the need for a

variance or amendment to the redevelopment plan. The judge denied the motion

on May 12, 2023, and denied reconsideration on August 8, 2023. ERUR now

appeals from both orders, essentially arguing the judge abused his discretion.

We affirm.

I.

For context, we begin our analysis by briefly summarizing the pertinent

principles that undergird Mount Laurel litigation. As our Supreme Court

explained, "[t]he Mount Laurel series of cases recognized that the power to zone

carries a constitutional obligation to do so in a manner that creates a realistic

opportunity for producing a fair share of the regional present and prospective

need for housing low- and moderate-income families." In re Adoption of

N.J.A.C. 5:96 & 5:97 (Mount Laurel IV), 221 N.J. 1, 3-4 (2015) (footnote

omitted). In 1975, the Court prohibited the discriminatory use of zoning powers

A-0238-23 3 and mandated that municipalities in their development activities affirmatively

"afford the opportunity for decent and adequate low[-] and moderate[-]income

housing," commensurate with "the municipality's fair share of the present and

prospective regional need therefore." S. Burlington Cnty. N.A.A.C.P. v. Mount

Laurel Twp. (Mount Laurel I), 67 N.J. 151, 188 (1975); see also S. Burlington

Cnty. N.A.A.C.P. v. Mount Laurel Twp. (Mount Laurel II), 92 N.J. 158, 205

(1983) (citing Mount Laurel I, 67 N.J. at 174) (reaffirming Mount Laurel I

principles)

The Court also created judicial remedies, which include a "builder's

remedy." See Mount Laurel II, 92 N.J. at 207. While noting that "the matter is

better left to the Legislature," the Court acknowledged that "a strong judicial

hand" must be used to "provide a realistic opportunity for housing, not

litigation" and to avoid "[c]onfusion, expense, and delay," which it deemed the

"primary enemies of constitutional compliance." Id. at 199, 212, 292. "In

response, the Legislature enacted the [Fair Housing Act (FHA), N.J.S.A.

52:27D-301 to -329.4], which created [the Council on Affordable Housing

(COAH)] and vested primary responsibility for assigning and determining

municipal affordable housing obligations in that body." Mount Laurel IV, 221

N.J. at 7.

A-0238-23 4 However, the Legislature since found that COAH's

inability to function ultimately led the Supreme Court in 2015 to order the temporary dissolution of the requirement that administrative remedies be exhausted prior to resolving affordable housing disputes before the court and allowed the courts to resume their role as the forum of first resort for evaluating municipal compliance with Mount Laurel obligations pursuant to guidelines laid out by the Supreme Court's order.

[N.J.S.A. 52:27D-302(l).]

The statute thus permits access to the judicial process for compliance by filing

declaratory judgment litigation. Mount Laurel IV, 221 N.J. at 20. These civil

actions are assigned to specially designated judges. Id. at 33, 36.

In 2024, the Legislature amended the FHA and codified the builder's

remedy in N.J.S.A. 52:27D-302. Under this statutory framework, a builder's

remedy lawsuit is an action filed by a real estate developer to compel a

municipality to allow the construction of a large, multi-family housing structure

or complex that includes affordable housing units. See In re Twp. of

Bordentown, 471 N.J. Super. 196, 221 (App. Div. 2022) ("A builder's remedy

provides a developer with the means to bring 'about ordinance compliance

through litigation.'" (quoting Mount Olive Complex v. Twp. of Mount Olive,

356 N.J. Super. 500, 505 (App. Div. 2003))). "A builder's remedy is only

appropriate 'after a [trial] court has had the opportunity to fully address

A-0238-23 5 constitutional compliance and has found constitutional compliance wanting. '"

Id. at 222 (alteration in original) (quoting Mount Laurel IV, 221 N.J. at 35-36).

"Consequently, only a municipality that satisfies its Mount Laurel obligations

'obtain[s] immunity from a builder's remedy.'" Ibid. (alteration in original)

(quoting Mount Laurel IV, 221 N.J. at 14).

II.

We now turn to the facts underlying this appeal. By way of background,

in October 2001, following an unrelated builder's remedy action against the

Borough, the Law Division ruled that the Borough's land use regulations were

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