Timothy Franzen, Intervenor v. City of Atlanta

CourtCourt of Appeals of Georgia
DecidedMarch 29, 2021
DocketA21A0267
StatusPublished

This text of Timothy Franzen, Intervenor v. City of Atlanta (Timothy Franzen, Intervenor v. City of Atlanta) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Timothy Franzen, Intervenor v. City of Atlanta, (Ga. Ct. App. 2021).

Opinion

FIFTH DIVISION MCFADDEN, C. J., BARNES, P. J., and RICKMAN, P.J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

DEADLINES ARE NO LONGER TOLLED IN THIS COURT. ALL FILINGS MUST BE SUBMITTED WITHIN THE TIMES SET BY OUR COURT RULES.

March 29, 2021

In the Court of Appeals of Georgia A21A0259. TIMOTHY FRANZEN, INTERVENOR et al. v. CITY OF ATLANTA. A21A0267. TIMOTHY FRANZEN, INTERVENOR et al. v. CITY OF ATLANTA.

RICKMAN, Presiding Judge.

This case involves two of three related bond validation proceedings, “all of

which concern the redevelopment of an area of downtown Atlanta commonly referred

to as “The Gulch.”“ Franzen v. Downtown Dev. Auth. of Atlanta, 309 Ga. 411, 411

(845 SE2d 539) (2020) (“Franzen I”).1 The Appellants opposed the bond validation

1 The bond validation proceedings at issue in this case involve the Westside Tax Allocation District, where The Gulch is located. The third related bond validation proceeding, which is not considered as part of this opinion, involved the Enterprise Zone Employment Act. In Franzen I, the Georgia Supreme Court determined that “[t]he record supports the trial court’s decision to defer to the City’s view that redevelopment of The Gulch serves a beneficial public purpose and upheld the trial court’s determination that the issuance of those Bonds was “sound, feasible, and below primarily by arguing that the Atlanta Board of Education and the Fulton

County Board of Commissioners did not have the authority to commit educational tax

dollars derived from certain tax allocation districts to the use of the proposed Gulch

developer for the Gulch redevelopment. Because we find that these arguments have

no merit, we affirm the trial court’s validation of the related bonds.

“Whether a proposal to issue bonds is sound, feasible, and reasonable is a

question for the trial court, and its findings about soundness, feasibility, and

reasonableness must be sustained on appeal if there is any evidence to support them.”

(Citation and punctuation omitted.) Savage v. State, 297 Ga. 627, 631-32 (3) (774

SE2d 624) (2015).

“The relevant facts show that, in 1998, the City of Atlanta (“City”), through its

City Council, adopted a Westside Redevelopment Plan that expressly declared the

City’s goal of redeveloping The Gulch, which had been blighted and underdeveloped

for some time. Franzen, 309 Ga. at 411 (1). According to the plan,

The Railroad Gulch – The ravine created in Atlanta by the railroads has long been a nuisance to the citizens of Atlanta as it has visually, socially, and physically divided the area since the early 1900’s. To overcome these conditions[,] the infusion of capital and the assistance

reasonable.” Id. at 431-432 (4).

2 of government is needed to redevelop this 150 acre area.... With the impending development of the new Atlanta Arena, [Tax Allocation District] funds could be used to help fill development gaps for tourism uses, ... office and retail uses, and other redevelopment needs and uses that might exist. Such developments offer Atlanta the best opportunity to redevelop the “[G]ulch” since the founding of the city over 150 years ago.

Id. at 411–12 (1).

The Redevelopment Powers Law encourages redevelopment “of economically

and socially depressed areas” because “these areas contribute to or cause

unemployment, limit the tax resources of counties and municipalities, and create a

greater demand for government services and, in general, have a deleterious effect

upon the public health, safety, morals, and welfare.” OCGA §§ 36-44-1; 36-44-2. “To

encourage such redevelopment, it is essential that the counties and municipalities of

this state have additional powers to form a more effective partnership with private

enterprise to overcome economic limitations that have previously impeded or

prohibited redevelopment of such areas.” OCGA § 36-44-2.

A political subdivision,

may exercise any powers necessary or convenient to carry out the purposes of the [Redevelopment Powers Law], including but not limited

3 to, the power to: . . . [c]ause redevelopment plans to be prepared, to approve by resolution the plans, and to implement the provisions and effectuate the purposes of the plans; [c]reate within redevelopment areas tax allocation districts and define the boundaries thereof or designate an entire redevelopment area as a tax allocation district; . . . [i]ssue tax allocation bonds[.]

OCGA § 36-44-5 (a) (2), (3), and (5).

A tax allocation district is defined as “a contiguous geographic area within a

redevelopment area which is defined and created by resolution of the local legislative

body of a political subdivision . . . for the purpose of issuing tax allocation bonds to

finance, wholly or partly, redevelopment costs within the area.” OCGA § 36-44-3

(13). Tax allocation bonds are “one or more series of bonds . . . issued by a political

subdivision to finance, wholly or partly, redevelopment costs within a tax allocation

district and which are issued on the basis of pledging for the payment or security for

payment of such bonds positive tax allocation incrementsrederived from the tax

allocation district.” OCGA § 36-44-3 (12). Tax allocation increments are derived

4 from an increase in ad valorem property tax2 revenues resulting from redevelopment.

See OCGA § 36-44-3 (14).

In 1998, the City created the Westside Tax Allocation District (“TAD”) when

it adopted the Westside Development Plan. Thereafter, the Atlanta Board of

Education, passed a resolution consenting to the inclusion of its ad valorem real

property taxes in the computation of the tax allocation increments for the Westside

TAD. Likewise, the Fulton County Board of Commissioners passed a similar

resolution, consenting to the inclusion of its ad valorem real property taxes in the

computation of the tax allocation increments for the Westside TAD through 2023.

Twenty years later, in 2008, the City Council passed a resolution amending the

termination date of the Westside TAD from December 31, 2023 to December 31,

2038. Fulton County then amended its 1998 resolution and extending its consent

through 2038, with certain conditions.

After the bond validation proceedings were initiated in both of these cases, the

Atlanta Board of Education adopted the 2018 resolution which stated that “[n]o

2 Ad valorem property taxes are defined as “all ad valorem property taxes levied by each political subdivision and each county and independent board of education consenting to the inclusion of that board of education’s property taxes as being applicable to a tax allocation district” subject to a few defined exceptions. OCGA § 36-44-3 (1).

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Timothy Franzen, Intervenor v. City of Atlanta, Counsel Stack Legal Research, https://law.counselstack.com/opinion/timothy-franzen-intervenor-v-city-of-atlanta-gactapp-2021.