May Collings v. Seattle Department Of Construction & Inspection

CourtCourt of Appeals of Washington
DecidedJuly 24, 2023
Docket83888-1
StatusUnpublished

This text of May Collings v. Seattle Department Of Construction & Inspection (May Collings v. Seattle Department Of Construction & Inspection) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
May Collings v. Seattle Department Of Construction & Inspection, (Wash. Ct. App. 2023).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

MAY COLLINGS, No. 83888-1-I

Appellant, DIVISION ONE v.

SEATTLE DEPARTMENT OF UNPUBLISHED OPINION CONSTRUCTION & INSPECTION,

Respondent.

SMITH, C.J. — The City of Seattle Department of Construction and

Inspections cited May Collings for violating sections of the Seattle Municipal

Code and the Seattle Residential Code. Almost a year after an order upholding

the violations was issued, Collings filed a petition under the Land Use Petition

Act (LUPA), chapter 36.70C RCW, in King County Superior Court. LUPA does

not apply when local jurisdictions are required by law to enforce their ordinances

in local forums, such as municipal courts. The superior court concluded this

exception to LUPA applied and that it did not have subject matter jurisdiction over

an appeal from a Seattle Residential Code violation and dismissed the case.

On appeal, Collings raises several issues. She contends that (1) the court

erred in dismissing the case for lack of subject matter jurisdiction; (2) the court

improperly conducted the motion to dismiss hearing; and (3) the court erred in

denying her motion to reconsider the dismissal. Finding no error, we affirm. No. 83888-1-I/2

FACTS

In February 2017, the City of Seattle Department of Construction and

Inspections sent a letter to May Collings denying her application for an exemption

from the City’s Environmentally Critical Areas ordinance (ECAO), Seattle

Municipal Code (SMC) Chapter 25.09, which regulates development in flood-

prone areas, wetlands, riparian corridors, and other at-risk areas. The City

denied her application because of a stream running through her property, which

would need to be protected in accordance with the ordinance. In late 2018,

Collings’s building permit was approved with the condition that any development

needed to include a 50-foot buffer between the house location and the stream.

In October 2019, the City received a complaint that Collings was

constructing her house within the 50-foot stream buffer. An inspection confirmed

these allegations. The City issued a notice of violation (NOV) in November 2019,

citing violations of the Seattle Residential Code (SRC) and the ECAO. The NOV

required Collings to submit an “as-built site survey,” a formal documentation of

how the building was constructed. Collings submitted the requested survey,

which showed that the distance from the house to the west edge of the stream

ranged between 42 and 43 feet. The City then issued an amended NOV,

providing Collings with options to correct the violation. In response, Collings

submitted a revision plan, including steps to mitigate any environmental damage

caused by not following the approved building plans. In March 2021, the City

2 No. 83888-1-I/3

issued a third NOV, which ordered Collings to make additional building

corrections and noted corrections that she had already completed.

Collings sought review of the third NOV by the Department of Construction

and Inspections Director. The Director sustained the violations.1

Almost a year later, Collings filed a petition under the Land Use Petition

Act (LUPA) in King County Superior Court seeking review of the Director’s order.

The City moved to dismiss her appeal, arguing that the court lacked subject

matter jurisdiction to hear the case and, in the alternative, that the appeal was

untimely.

In accordance with COVID-192 guidelines in place at that time, the hearing

on the City’s motion to dismiss was conducted telephonically.3 However, a few

moments into the hearing, Collings was temporarily disconnected. After Collings

was reconnected to the call, the judge summarized the arguments she had

missed and gave the City the opportunity to provide any additional information it

felt the court had not included. The court then asked Collings if she was

1 Though the Director’s order does not explicitly mention the ECAO, it is implicitly implicated by the stream buffer violation. Collings was cited for not following the approved building permits—a violation of the Residential Code—by not including the stream buffer required by her building permit—an ECAO requirement. 2 COVID-19 is the World Health Organization’s official name for

“coronavirus disease 2019,” a severe, highly contagious respiratory illness that quickly spread throughout the world after being discovered in December 2019. 3 Court Operations During the COVID-19 Pandemic, KING COUNTY SUPERIOR

CT. (last updated Jan. 5, 2021), https://kingcounty.gov/courts/superior-court/get- help/COVID19.aspx.

3 No. 83888-1-I/4

prepared to proceed with the hearing, to which Collings replied, “Yes.” At the

end of the hearing, the court granted the City’s motion and dismissed the case.

Collings filed several motions for reconsideration and accompanying notices

of hearing on March 14 and 15, 2022, the last of which was noted for March 30,

2022, and then filed the present appeal on April 8, 2022.

ANALYSIS

We are presented with three issues on appeal. First, whether the trial

court had subject matter jurisdiction over Collings’s appeal under LUPA and, if

so, whether the court properly dismissed the appeal. We conclude that the court

had subject matter jurisdiction over a portion of Collings’s appeal, but properly

dismissed the entire case as her appeal was untimely. Second, whether court

erred in conducting a telephonic hearing rather than a hearing via Zoom. We

conclude that the court did not err and that Collings waived this issue by not

raising it below. Finally, whether the court erred in declining to hear Collings’s

motion for reconsideration. Because Collings filed the present appeal before the

court could rule on her motion, the court did not decline to hear the motion—it

simply did not have the authority to do so once the appeal was filed.

LUPA

We first consider whether the superior court had subject matter jurisdiction

under LUPA to consider Collings’s petition. Collings asserts that the court had

jurisdiction over her ECAO citation, but denies that she was cited under SMC

Title 22, which is exempt from LUPA. She therefore argues that the court had

4 No. 83888-1-I/5

jurisdiction. The record demonstrates that she was cited under both provisions.

While we agree that the ECAO violation is subject to LUPA—and that the court

had jurisdiction over that citation—Collings’s LUPA challenge was untimely.

Thus, the court did not err in dismissing her petition.

LUPA is the exclusive means for obtaining judicial review of land use

decisions. RCW 36.70C.030. A “land use decision” is a final determination by a local jurisdiction’s body or officer with the highest level of authority to make the determination, including those with authority to hear appeals, on . . . [a]n interpretative or declaratory decision regarding the application to a specific property of zoning or other ordinances or rules regulating the improvement, development, modification, maintenance, or use of real property.

RCW 36.70C.020(2).

A petition for review of a land use decision under LUPA must be filed

within 21 days of the decision’s issuance.

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May Collings v. Seattle Department Of Construction & Inspection, Counsel Stack Legal Research, https://law.counselstack.com/opinion/may-collings-v-seattle-department-of-construction-inspection-washctapp-2023.