Oom Living, Llc, Res. V. City Of Seattle; Seattle Public Utilities, Apps.

Court of Appeals of Washington·Decided August 17, 2026·No. 88426-3·Unpublished

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

OOM LIVING, LLC, a Washington limited liability company, and No. 88426-3-I JENNIFER EGUSA WALDEN, DIVISION ONE

Respondents,

UNPUBLISHED OPINION

v.

CITY OF SEATTLE, a Washington municipal corporation, and SEATTLE PUBLIC UTILITIES,

Appellants.

MANN, J. — This case arises from Oom Living LLC’s application to the City of Seattle for a water service connection for a new residential development in West Seattle. To obtain a water availability certificate, the City, through Seattle Public Utilities (SPU), required that Oom Living construct a 173-foot water main line extension. Oom Living sued the City for declaratory and injunctive relief and sought damages. Oom Living argued that the City’s requirement to construct a water main extension violated city code, was an unconstitutional exaction, and violated RCW 82.02.020. On cross- motions for summary judgment, the trial court ruled in favor of Oom Living and entered a stipulated judgment for damages, attorney fees, and interest.

We affirm the trial court’s declaratory ruling that the City’s water main extension requirement conflicted with city code. We also affirm the ruling requiring that the City approve Oom Living’s connection of Parcel Y to the water main under SW Elmgrove Street.

We reverse the trial court’s conclusion that the City was liable under 42 U.S.C. § 1983 because the water main requirement was an exaction subject to Nollan/Dolan and Koontz. 1 We also reverse the trial court’s conclusion that the City was liable under RCW 82.02.020. We remand to the trial court to vacate the judgment awarding compensatory damages, attorney fees, and pre- and postjudgment interest under 42 U.S.C. § 1983 and RCW 82.02.020.

Affirmed in part, reversed in part, and remanded.

I. FACTS

A. Background

In May 2022, Oom Living 2 purchased two lots located at 8004 and 8014 39th Avenue SW in West Seattle. The properties span the entire east side of 39th Avenue

1 Nollan v. Cal. Coast Comm’n, 483 U.S. 825, 107 S. Ct. 3141, 97 L. Ed. 2d 677 (1987); Dolan v.

City of Tigard, 512 U.S. 374, 114 S. Ct. 2309, 129 L. Ed.2d 304 (1994); Koontz v. St. Johns River Water Mgmt. Dist., 570 U.S. 595, 133 S. Ct. 2586, 186 L. Ed. 2d 697 (2013).

2 Oom Living is a Washington limited liability company. Jennifer Egusa Walden is the managing

and majority member of Oom Living.

SW between SW Monroe Street on the north and SW Elmgrove on the south. Each of the two lots were connected to water service provided by SPU—with 8004 connecting to the main under SW Monroe and 8014 connecting to the main under SW Elmgrove. There is no water main under this block of 39th Avenue SW.

In October 2022, Oom Living applied to subdivide the two lots into three lots, known as parcels X,Y, and Z. Before submitting the subdivision application, Oom Living sought direction from the Seattle Department of Construction and Inspection (SDCI) about the configuration of the lots. SDCI and Oom Living ultimately decided on the following configuration:

The configuration of Parcel Y is known as a “flagpole lot” since it is shaped like a flag on a pole. This configuration was done at the recommendation of SDCI to facilitate a side sewer connection on SW Elmgrove Street.

State law required that Oom Living provide evidence of an adequate water supply, which is done through obtaining a valid water availability certificate from SPU. Seattle Municipal Code (SMC) 21.04.020; RCW 19.27.097(1)(a). Oom Living applied to SPU to obtain the water availability certificate for Parcel Y by connecting to the abutting water main on SW Elmgrove Street.

On April 6, 2023, SPU issued a water availability certificate that was conditioned on the requirement that Oom Living “design and install approximately 173 feet of 8-inch ductile iron pipe water main in 39th Ave SW extending from SW Elmgrove Street to northern parcel boundary [of Parcel Y].” SPU explained that SMC 21.04.061 authorizes the Director to implement rules relating to requiring the construction of water mains. SPU explained that Director’s Rule WTR-440 implements the city code and prohibits flagpole lots for water main connections.

Oom Living estimated the cost to construct a new water main extension under 39th Avenue SW would be approximately $355,000.

B. Procedural History

Oom Living first sought administrative review of the water main extension requirement. Oom Living argued that Parcel Y abuts a street with an existing suitable water main and should be connected to the water main under city code. Oom Living asserted that the City’s reliance on Director Rule WTR-440 as a basis for requiring the extension conflicted with city code and violated the state and federal constitutions. Oom

Living also argued that the requirement constituted a violation of RCW 82.02.020. SPU rejected the appeal and upheld the water main extension requirement.

Oom Living sued the City in King County Superior Court seeking declaratory and injunctive relief and damages. Oom Living sought declaratory judgment concluding that the City’s water main extension requirement violated state and local law and/or the state and federal constitutions. While the matter was pending, the City allowed Oom Living to establish a temporary connection for Parcel Y to the water main under SW Elmgrove Street, subject to the requirement that Oom Living post a bond in the amount of $355,000.

The parties cross-moved for summary judgment. The trial court granted Oom Living’s motion and denied the City’s. The trial court entered declaratory judgment as follows:

a. The City’s conditioning of the Water Availability Certificate violated the plain language of Chapter 21.04 SMC and/or SPU Director’s Rule WTR-

440. To the extent the City interprets subsection VI.C.3.c of WTR-440 to authorize the water main extension condition, its interpretation of that subsection conflicts with the City code and does not follow from the subsection’s plain language.

b. To the extent that SPU has adopted an unwritten policy of prohibiting private service line connections to an abutting water main via a legally established flag lot configuration, its application of that unwritten policy to Oom Living’s application for a water availability certificate was arbitrary and capricious.

c. The City’s water main extension constitutes a fee or charge on development subject to RCW 82.02.020. The City has failed to meet its burden of showing that the extension was “reasonably necessary as a direct result of the proposed development or plat to which the dedication of land or easement is to apply.” Thus, the condition violates RCW 82.02.020.

d. The City is enjoined from enforcing the water main extension condition and is directed to issue a water availability certificate approving Plaintiffs[’]

connection to the abutting water main under SW Elmgrove Street.

The court also granted Oom Living’s claim for liability under 42 U.S.C. § 1983 as follows:

a. The City’s demand that Plaintiffs fund the design and installation of a water main extension as a condition of issuing a water availability certificate is an exaction subject to Nollan v. California Coastal Comm’n, 483 U.S. 825 (1987), Dolan v. City of Tigard, 512 U.S. 374 (1994), and Koontz v. St. Johns River Water Management District, 570 U.S. 595 (2013).

b. The City has not met its burden of demonstrating that the condition bears an essential nexus or is roughly proportionate to the impacts of Plaintiffs’ proposed connection to the abutting water main under SW Elmgrove Street. Thus, the condition violates the federal doctrine of unconstitutional conditions.

c. Plaintiffs suffered a cognizable constitutional injury the moment the City imposed the unconstitutional condition on the water availability certificate.

d. The City was acting under the color of state law when it placed the water main extension condition on Plaintiffs’ water availability certificate.

e. The City is liable for damages under 42 U.S.C. § 1983, the amount of which to be proven at trial.

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