Township of Manalapan v. Anthony Gentile (083137)(Monmouth County & Statewide)

CourtSupreme Court of New Jersey
DecidedJune 2, 2020
DocketA-14-19
StatusPublished

This text of Township of Manalapan v. Anthony Gentile (083137)(Monmouth County & Statewide) (Township of Manalapan v. Anthony Gentile (083137)(Monmouth County & Statewide)) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Township of Manalapan v. Anthony Gentile (083137)(Monmouth County & Statewide), (N.J. 2020).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court. In the interest of brevity, portions of an opinion may not have been summarized.

Township of Manalapan v. Anthony Gentile (A-14-19) (083137)

Argued February 4, 2020 -- Decided June 2, 2020

SOLOMON, J., writing for the Court.

The Township of Manalapan challenges the condemnation award in favor of defendants entered after a jury trial. The issue is whether it was error to admit testimony that the condemned property’s highest and best use would require a variance without first determining whether there is a reasonable probability the variance would be granted.

Defendants’ property was in an area zoned as R20 (residential) until 2002, when the Township rezoned it to RE (residential environmental). The R20 zone allows for single family dwellings on half-acre lots, whereas the RE zone provides for single family dwellings on lots of no fewer than three acres. Therefore, undivided land in an R20 zone would have a greater fair market value than the same land in an RE zone.

At trial, the Township’s expert explained that, in arriving at his estimate of $2.83 million, he assumed the continued application of RE zoning and evaluated the property by reference to the sale price of similar properties. He acknowledged, however, that unlike the subject property, those he compared did not have sanitary sewer or municipal water systems. By contrast, defendants’ expert planner opined, over the Township’s objection, that the highest and best use of the subject property would be to divide it into smaller lots, as would be permitted in an R20 zone. He explained that such use of the property would yield “up to six times the density” under the current RE zoning but that “the Township committee would have to agree to change the zone.” Importantly, he did not offer any opinion about the value of the property as is or if a variance were granted, or even about the probability that such a variance would be granted. Indeed, in ruling on the Township’s objection to his testimony, the court cautioned defendants’ expert not to “opin[e] on possibilities or likelihoods or odds or procedures about getting variances.”

The Township moved for judgment at the close of evidence. The court granted the motion in part, ordering defense counsel not to argue in closing that, when calculating the property’s value, the jury could assume a variance will be granted. But the court allowed the question of fair market value to go to the jury. During closing, defense counsel reminded the jurors that the subject property is surrounded by an R20 zone and repeatedly referenced the possibility of rezoning. 1 The court instructed the jurors to decide the market value of the property using the expert opinions if they “find those opinions helpful.” The judge instructed that if the jurors were to reject all expert testimony, then they could “come up with another figure for the fair market value of the property,” so long as that figure is based on the evidence presented. The jury returned a unanimous verdict awarding defendants $4.5 million.

The Township filed post-trial motions claiming that the Court’s decision in Borough of Saddle River v. 66 East Allendale, LLC, 216 N.J. 115 (2013), required the trial court to conduct an N.J.R.E. 104 hearing as to the reasonable probability of a variance before admitting any testimony by defendants’ expert that the subject property’s highest and best use would require R20 zoning. The trial court denied those motions, and the Appellate Division affirmed. The Court granted certification, “limited to the issue of whether the Appellate Division erred in concluding that a plenary hearing regarding the ‘reasonable probability’ of a zoning change was not required before the commencement of trial.” 239 N.J. 495 (2019).

HELD: As the Court explained in Borough of Saddle River v. 66 East Allendale, LLC, evidence that risks misleading the jury into assuming a zoning variance for purposes of calculating a property’s value must not be admitted absent a judicial finding it is reasonably probable that the variance will be obtained. 216 N.J. 115, 142 (2013). Therefore, the trial court erred by allowing the jury to consider testimony that the highest and best use of the subject property would require a variance without first confirming the probability of securing that variance.

1. A municipality has the authority to take private property for a public use provided that just compensation is paid to the property owner. Just compensation is the fair market value of the property as of the date of taking. The fair market value generally considers “the property’s highest and best use.” To constitute the ‘highest and best use,’ a use must be ‘1) legally permissible, 2) physically possible, 3) financially feasible, and 4) maximally productive. (pp. 10-11)

2. Whether potential zoning changes might be considered in determining a property’s best use or whether such consideration would run afoul of the “legally permissible” requirement was addressed in Commissioner of Transportation v. Caoili, where the Court held that “the jury may consider a potential zoning change affecting the use of the property provided the court is satisfied that the evidence is sufficient to warrant a determination that such a change is reasonably probable.” 135 N.J. 252, 265 (1994) (emphasis added). (pp. 11-12)

3. In 66 East Allendale, the Court applied those principles in the context of a purported highest and best use that could be achieved only if a variance were granted and held that, “only when the trial court has first determined that the evidence is of a quality to allow the jury to consider the probability of a zoning change should the jury be permitted to 2 assess a premium based on that zoning change . . . . The gatekeeping function was assigned to the judge specifically to screen the jury from hearing mere speculation.” 216 N.J. at 142. From 66 East Allendale derives the following overarching approach to predicating highest and best use analyses on not-yet obtained zoning variances. A use that does not conform to current zoning is not legally permissible and so cannot be a property’s highest and best use. See id. at 137. However, while a property’s highest and best use “is ordinarily evaluated in accordance with current zoning ordinances[,] [c]ertain circumstances may permit valuation to include an assessment of a change in the permitted use of a property, but only if there is a reasonable probability that a zoning change would be granted.” Id. at 119. That substantive determination of probability must account for “the standard that would govern the particular zoning change under consideration.” Id. at 143. In making that determination, the trial court must examine the parties’ evidence as to the probability of the zoning change to “determine whether [the court] can render its required determination based on the papers.” Ibid. If that determination cannot be made on the written submissions alone, the court shall conduct a pretrial Rule 104 hearing to resolve the issue. Id. at 142-43. (pp. 12-16)

4. The question presented in this case was answered in 66 East Allendale. The trial court here neglected its role as gatekeeper by letting the jury consider evidence about a variance without following the procedures and standards laid out in 66 East Allendale. Because there was no finding that a variance from RE to R20 would likely be granted, the jury should not have been permitted to evaluate the property on any basis other than its highest and best use “in accordance with current zoning ordinances.” See id. at 119 (emphasis added).

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Township of Manalapan v. Anthony Gentile (083137)(Monmouth County & Statewide), Counsel Stack Legal Research, https://law.counselstack.com/opinion/township-of-manalapan-v-anthony-gentile-083137monmouth-county-nj-2020.