Leonard v. New Castle County

CourtSuperior Court of Delaware
DecidedApril 5, 2021
DocketN20A-07-004 ALR
StatusPublished

This text of Leonard v. New Castle County (Leonard v. New Castle County) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Leonard v. New Castle County, (Del. Ct. App. 2021).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

HAROLD LEONARD, ) ) Appellant, ) ) C.A. No. N20A-07-004 ALR v. ) ) NEW CASTLE COUNTY, ) NEW CASTLE COUNTY BOARD ) OF LICENSE, INSPECTION AND ) REVIEW, SHANE MILLER, in his ) Official Capacity as Code ) Enforcement Officer, and JACK ) GAHAN, in his Official Capacity as ) Chief Filed Supervisor, ) ) Appellees. )

Submitted: March 24, 2021 Decided: April 5, 2021

Upon Writ of Certiorari from the New Castle County Board of License, Inspection and Review AFFIRMED

MEMORANDUM OPINION

James H. Edwards, Esquire, Hockessin, Delaware, Attorney for Appellant.

Karen V. Sullivan, Esquire, New Castle County Office of Law, New Castle, Delaware, Attorney for Appellees.

Rocanelli, J. This matter involves a citation issued by New Castle County Department of

Land Use, Division of Code Enforcement to a homeowner for storage of inoperable

vehicles on his property in violation of the New Castle County Property Maintenance

Code.1 Harold Leonard, the owner of the property at issue, has been cited by New

Castle County many times over the past several years. The record reflects that

neighbors have made complaints about the condition of the property at issue. In

addition to the vehicle which is the subject of New Castle County citations for the

storage of inoperable vehicles, the record also includes photographs of the unkempt

condition of the property, including vehicles which have been enveloped by weeds

and vehicle tires with moss growing on them.

The specific citation at issue here involves a Chevrolet sedan with

VIN#31847J181729 (“Vehicle”). On May 24, 2019, a New Castle County Code

Enforcement Officer (“NCC Enforcement Officer”) issued ticket number 2031353

1 Section 7.01.001 of the New Castle County Code adopts the International Property Maintenance Code, 2018 edition, published by the International Code Council, Inc. as the New Castle County Property Maintenance Code. Section 7.01.002 of the New Castle County Code makes certain modifications to the International Property Maintenance Code, 2018 edition, and refers to the sections as “Section PM ___.” (“Section PM ___” format will be used as the form of citation for the cited provisions of the Property Maintenance Code.) The Property Maintenance Code specifies minimum requirements and standards for maintaining premises. (International Property Maintenance Code 2018 § 101.2 (Scope).)

1 (“Ticket”) to Leonard charging a violation of Section PM 302.8.3 of the New Castle

County Property Maintenance Code for the storage of an inoperable or unregistered

vehicle.2 The Ticket noted the Vehicle was parked in the driveway and did not have

any interior seating (except driver’s seat) or ignition switch and that it was missing

several engine parts. The NCC Enforcement Officer concluded these missing parts

rendered the vehicle inoperable.

Leonard filed a timely appeal of the Ticket to the New Castle County

Department of Land Use. After an administrative hearing, the hearing officer

concluded that the violation existed at the time the Ticket was issued. Leonard

appealed the decision of the administrative hearing officer to the New Castle County

Board of License, Inspection and Review (“LIR Board”).

Leonard was represented by counsel at the March 10, 2020 LIR Board

hearing. The LIR Board considered the testimony of Leonard and the NCC

Enforcement Officer and considered the documentary evidence submitted by

Leonard and New Castle County. The LIR Board issued a decision on June 24, 2020

2 The New Castle County Department of Land Use, Division of Code Enforcement (“Code Enforcement”) is charged with enforcing the Property Maintenance Code pursuant to the processes specified in the Code. When a NCC Enforcement Officer “determines that there has been a violation of this Chapter or has reasonable grounds to believe that a violation has occurred, notice shall be given to the owner or persons responsible for the property.” (Section PM 106.3.1.1; see also Section PM 106.3.1.2.1.) 2 (“LIR Decision”) which concluded that the Ticket for an inoperable vehicle was

properly issued.

Leonard has filed a petition for writ of certiorari from the LIR Decision.

STANDARD OF REVIEW

“A petition for writ of certiorari ‘is simply a form that calls up, for review,

the record from the lower court or tribunal.’”3 The purpose of a writ of certiorari is

to “permit the higher court to review the conduct of a lower tribunal record.”4 “The

standard for reviewing a petition for writ of certiorari is ‘strictly limited.’”5 This

Court may not weigh evidence or review the lower tribunal’s factual findings.6

Moreover, this Court may not “consider the case on its merits.”7

The scope of review is whether the lower tribunal “(1) committed errors of

law, (2) exceeded its jurisdiction, or (3) proceeded irregularly.”8 As explained by

the Delaware Supreme Court, a reviewing court needs to determine whether relief

from the judgment would be appropriate on any of the three grounds.9 A decision

3 Millsboro Fire Co. v. State Fire Prevention Comm’n, 2014 WL 5396158, at *1 (Del. Super. Oct. 21, 2014) (quoting Maddrey v. Just. of Peace Ct. 13, 956 A.2d 1204, 1213 (Del. 2008)). 4 Id. (quoting Maddrey, 956 A.2d at 1213). 5 Black v. New Castle Cty. Bd. of License, 117 A.3d 1027, 1030 (Del. 2015) (citing Matter of Butler, 609 A.2d 1080, 1081 (Del. 1992)). 6 Black, 117 A.3d at 1031. 7 Id. (quoting Christiana Town Ctr., LLC v. New Castle Cnty., 2004 WL 2921830, at *2 (Del. Dec. 16, 2004) (TABLE)). 8 Maddrey, 956 A.2d at 1213. 9 See id. 3 by a lower tribunal “will be reversed for an error of law . . . when the record

affirmatively shows that the lower tribunal has ‘proceeded illegally or manifestly

contrary to law.’”10 “Reversal on jurisdictional grounds is appropriate ‘only if the

record fails to show that the matter was within the lower tribunal’s personal and

subject matter jurisdiction.’”11 Finally, “[r]eversal for irregularities of proceedings

occurs ‘if the lower tribunal failed to create an adequate record for review.’”12

DISCUSSION

Leonard focuses his arguments on contentions of legal error as well as a claim

of procedural irregularity with respect to application of the standard of review. First,

Leonard contends that consideration by the LIR Board of photographs amounted to

legal error. Specifically, Leonard contends the search warrant was unconstitutional

and therefore photographs taken when the warrant was executed should not have

been considered. This Court disagrees.

On May 2, 2019, a NCC Enforcement Officer observed what appeared to be

debris and inoperable vehicles on Leonard’s property and applied for a search

warrant to obtain evidence of the violations. On May 23, 2019, a Magistrate Judge

for the Justice of the Peace Court No. 11 issued a search warrant (the “Search

Warrant”) for the Property, to include “the exterior property area and the interior of

10 Id. at 1214 (quoting Christiana Town Ctr., LLC, 2004 WL 2921830, at *2). 11 Id. (quoting Christiana Town Ctr., LLC, 2004 WL 2921830, at *2). 12 Id. (quoting Christiana Town Ctr., LLC, 2004 WL 2921830, at *2). 4 vehicles.” A copy of the entire application and Search Warrant, including the

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Related

Christiana Town Center, LLC v. New Castle County
865 A.2d 521 (Supreme Court of Delaware, 2004)
In the Matter of Butler
609 A.2d 1080 (Supreme Court of Delaware, 1992)
Maddrey v. Justice of the Peace Court 13
956 A.2d 1204 (Supreme Court of Delaware, 2008)
Black v. New Castle County Board of License
117 A.3d 1027 (Supreme Court of Delaware, 2015)

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Bluebook (online)
Leonard v. New Castle County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leonard-v-new-castle-county-delsuperct-2021.