KATHY MCBRIDE VS. LT. GOVERNOR SHEILA Y. OLIVER (L-0919-19, MERCER COUNTY AND STATEWIDE)

CourtNew Jersey Superior Court Appellate Division
DecidedJune 15, 2021
DocketA-4683-18
StatusUnpublished

This text of KATHY MCBRIDE VS. LT. GOVERNOR SHEILA Y. OLIVER (L-0919-19, MERCER COUNTY AND STATEWIDE) (KATHY MCBRIDE VS. LT. GOVERNOR SHEILA Y. OLIVER (L-0919-19, MERCER COUNTY AND STATEWIDE)) 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
KATHY MCBRIDE VS. LT. GOVERNOR SHEILA Y. OLIVER (L-0919-19, MERCER COUNTY AND STATEWIDE), (N.J. Ct. App. 2021).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court."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-4683-18

KATHY MCBRIDE, PRESIDENT, TRENTON CITY COUNCIL, MARGE CALDWELL-WILSON, VICE PRESIDENT, TRENTON CITY COUNCIL, ROBIN M. VAUGHN, SANTIAGO RODRIGUEZ and GEORGE MUSCHAL, MEMBERS, TRENTON CITY COUNCIL,

Plaintiffs-Appellants, v.

LT. GOVERNOR SHEILA Y. OLIVER, COMMISSIONER, NEW JERSEY DEPARTMENT OF COMMUNITY AFFAIRS, DIVISION OF LOCAL GOVERNMENT SERVICES, REED GUSCIORA, MAYOR, CITY OF TRENTON,

Defendants,

and

MELANIE R. WALTER, DIRECTOR, NEW JERSEY DEPARTMENT OF COMMUNITY AFFAIRS, DIVISION OF LOCAL GOVERNMENT SERVICES,

Defendant-Respondent.

Submitted October 15, 2020 - Decided June 15, 2021

Before Judges Ostrer, Accurso and Vernoia.

On appeal from the Superior Court of New Jersey, Law Division, Mercer County, Docket No. L-0919-19.

Grace, Marmero & Associates, LLP, attorneys for appellants (Albert K. Marmero, on the briefs).

Gurbir S. Grewal, Attorney General, attorney for respondent (Melissa H. Raksa, Assistant Attorney General, of counsel; Steven M. Gleeson and Dominic Giova, Deputy Attorneys General, on the brief).

PER CURIAM

Plaintiffs Trenton City Council President Kathy McBride, Vice President

Marge Caldwell-Wilson, and Council Members Robin M. Vaughn, Santiago

Rodriguez and George Muschal, 1 appeal from a June 7, 2019 order entered by

Judge Jacobson transferring to this court their complaint to permanently enjoin

defendants Lieutenant Governor Sheila Y. Oliver, Commissioner, New Jersey

1 Council Members Santiago Rodriguez and George Muschal joined the suit after the filing of the complaint. A-4683-18 2 Department of Community Affairs; Melanie R. Walter, Director, New Jersey

Department of Community Affairs, Division of Local Government Services; and

Trenton Mayor Reed Gusciora from taking any action to implement any budget

or tax rate inconsistent with the budget approved by City Council on March 28,

2019, and dismissing the claims against the Lieutenant Governor and the Mayor

with prejudice. Because the City Council's subsequent adoption of a Fiscal Year

2019 budget inconsistent with the one it approved on March 28 has made the

relief requested by plaintiffs impossible, leaving aside their failure to avail

themselves of the administrative remedies provided them by the Legislature

under N.J.S.A. 52:27BB-15, we dismiss the matter as moot.

Although the dispute has a tortured history, the essential facts, for our

purposes, are easily summarized. Under the State's Local Budget law, N.J.S.A.

40A:4-1 to -89, every municipality must adopt an annual budget on a cash basis,

N.J.S.A. 40A:4-3, which must have been previously approved by the Director

of the Division of Local Government Services, N.J.S.A. 40A:4 -10. See City of

Atlantic City v. Cynwyd Invs., 148 N.J. 55, 65 (1997) (explaining the

requirement "insures that, absent unforeseen emergencies, local gove rnments

will pay for the expenses they incur with cash actually collected or received

during the fiscal year"). For those municipalities, such as Trenton, that are

A-4683-18 3 dependent on discretionary state aid under the Transitional Aid to Localities

program, N.J.S.A. 52:27D-118.42a, the Director "exercises broad oversight of

the municipality's operations, focusing on, but not limited to, its fiscal

management." Redd v. Bowman, 223 N.J. 87, 113 (2015) (noting "[t]he Senate

Budget and Appropriations Committee declared that '[a]pplying for aid under

this program is a declaration that the municipality is not capable of managing

its finances without special State assistance and intervention'" (quoting S.

Budget & Appropriations Comm. Statement to S. 3118 (Dec. 8, 2011))).

Trenton has been a recipient of discretionary aid through the Transitional

Aid to Localities program since the program's inception in 2011, and thus is well

acquainted with the program's requirements. One of those requirements is that

it enter annually into a Memorandum of Understanding with the Division

subjecting the City to specific terms and conditions of Division oversight and

control of its finances. See N.J.S.A. 52:27D-118.42a(a). 2

2 The statute provides in pertinent part:

a. The Director of the Division of Local Government Services in the Department of Community Affairs shall determine conditions, requirements, orders, and oversight for the receipt of any amount of grants, loans, or any combination thereof, provided to any municipality through the Transitional Aid to Localities

A-4683-18 4 Trenton operates under a Mayor and Council form of government under

the Faulkner Act. See N.J.S.A. 40:69A-32. In October 2018, Mayor Gusciora

submitted his proposed budget for Fiscal Year 2019 to the City Council. That

budget included a 0.114 tax rate levy increase, that is 11.4 cents per $100 of

assessed value, a total tax rate increase of approximately three percent. The City

Council accepted the budget but did not take action on it.

On March 21, 2019, following receipt of the City's final Transitional Aid

award letter, the Mayor submitted the draft budget to the Division, which the

Director approved as amended. The City Council failed to adopt the approved

budget. Instead, the City Council made amendments to the Director's approved

budget, including cutting several line-item expenses, such as reserves for

uncollected taxes and municipal liability, and reducing the tax levy increase to

program or any successor discretionary aid programs for municipalities in fiscal distress. Conditions, requirements, or orders deemed necessary by the director may include, but not be limited to, the implementation of government, administrative, and operational efficiency and oversight measures necessary for the fiscal recovery of the municipality, including but not limited to requiring approval by the director of personnel actions, professional services and related contracts, payment in lieu of tax agreements, acceptance of grants from State, federal or other organizations, and the creation of new or expanded public services. A-4683-18 5 0.05, which it resolved on March 28 to file with the Division "for certification

of the municipal [b]udget so amended." According to the Director, the City

Council's proposed six cent reduction in the tax rate would result in in a $1.5

million reduction in the municipal purposes tax levy compared to FY2018 and

would exacerbate a future deficit projected at over $10 million and a projected

structural gap of approximately $23 million.

The Director wrote to the Mayor and the City Council President in early

April cataloging the City's several financial violations of the Transitional Aid

MOU, including budget amendments that "reflect[] unsupported increases in

spending, declining reserves and fund balance, [and] under-budgeting of

essential line items," while decreasing the municipal levy, "resulting in an

expanding structural and operational deficit." Based on the City's "ongoing

failure to meet its Transitional Aid Program obligations," the Director advised

Trenton's Transitional Aid award would be reduced by over a quarter of a million

dollars.

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KATHY MCBRIDE VS. LT. GOVERNOR SHEILA Y. OLIVER (L-0919-19, MERCER COUNTY AND STATEWIDE), Counsel Stack Legal Research, https://law.counselstack.com/opinion/kathy-mcbride-vs-lt-governor-sheila-y-oliver-l-0919-19-mercer-county-njsuperctappdiv-2021.