HomeMy WebLinkAboutCover MemoCITY OF MIAMI
OFFICE OF THE CITY ATTORNEY
MEMORANDUM
TO: Honorable Mayor Members of the City Commission,
FROM: Jorge L. Fernan ity rrney ib
DATE: July 16, 200
RE: Masztal, et aL, ind 'visually and on behalf of those similarly situated v. City
of Miami, Florida, Case No: 98-11208 CA 31 (f/k/a Nagymihaly, et al. v.
City of Miami, Florida) and Masztal, et aL, individually and on behalf of
those similarly situated v. City of Miami, Florida, Case No: 05-2111 CA
31
(File No. 07-00890)
The attached proposed Resolution seeks authorization for settlement in the above -
referenced cases in the amount of $15,550,000.
Background
The above class action lawsuits have been pending since 1998 and 2005 respectively.
The City adopted Ordinance 1158, on January 13, 1998, authorizing a Fire -Rescue
Assessment pursuant to the broad home rule powers granted under Chapter 166, Florida
Statutes and controlling case law. The original Nagymihaly plaintiffs, Nagymihaly, et al. v.
City of Miami, Florida, challenged the City of Miami fire/rescue assessments levied for FY 97-
98 and FY 98-99, by claiming that the assessments were invalid taxes and that the
apportionment methodology used in calculating the fire/rescue assessment rates was
unreasonable.
On May 4, 2004, the trial court issued an Order in Nagymihaly v. City of Miami holding
the EMS portion of the challenged fire/rescue assessments (FY 97-98 & FY 98-99) invalid.
The trial court's May 4, 2004, Order did not invalidate the statutory language authorizing
assessments for fire services. On May 24, 2004, the City and the original Nagymihaly plaintiffs
participated in a mediation conference. On May 26, 2004, the agreement to settle the
"invalidity" portion of the Nagymihaly suit was announced to the trial court with the proviso
that the settlement was subject to approval by the City Commission. The claims attacking the
apportionment methodology used in calculating the fire/rescue assessments for FY 97-98 and
FY 98-99, were not covered by the settlement proposal.
On November 18, 2004, the City Commission approved Resolution No. 04-0748,
thereby authorizing the settlement of the "validity" portion of the challenge by the Nagymihaly
plaintiffs for $7 million. On December 5, 2004, the City disbursed the first $3.5 million
installment of settlement payments to Adorno & Yoss trust account. On January 28, 2005, the
new plaintiffs (Masztal, et al., individually and on behalf of those similarly situated v. City of
Miami, Florida, Case No: 98-11208 CA 31) filed a motion to intervene in Nagymihaly.
On June 6, 2005, the City filed a motion to set aside the Nagymihaly partial settlement.
On March 17, 2006, Judge Lopez issued an Order setting aside the Nagymihaly partial
settlement agreement. The trial court found that there had not been a meeting of the minds and
allowed the settlement to be set aside on the grounds of unilateral mistake committed by the
city commission which did not rise to level of inexcusable lack of due care. As of the date of
this memo, the City has recovered $1.99 million of the settlement payment made in December
2004. At this time, Judge Lopez's order is on appeal to the Third District Court of Appeal.
The Third Amended Complaint filed by new plaintiffs, Masztal, et al., individually and
on behalf of those similarly situated v. City of Miami, Florida, Case No: 98-11208 CA 31
(f/k/a Nagymihaly, et al. v. City of Miami, Florida) and Masztal, et al., individually and on
behalf of those similarly situated v. City of Miami, Florida, Case No: 05-2111 CA 31, seeks
recovery of all alleged illegally collected assessments (fire/rescue &fire) imposed through FY
2006-2007.
Terms and Conditions of the Proposed Settlement Agreement and Release
The purpose of the proposed Settlement Agreement and Release discussed herein is to
forever settle the claims stated in the Class Action complaint against the City in Masztal, et
al., individually and on behalf of those similarly situated v. City of Miami, Florida, Case No:
98-11208 CA 31 (f/k/a Nagymihaly, et al. v. City of Miami, Florida) and Masztal, et aL,
individually and on behalf of those similarly situated v. City of Miami, Florida, Case No: 05-
2111 CA 31.
The class includes or will include all persons or entities that owned property in the City
and paid the Fire/Rescue Assessment (enacted from FY 1997-1998 through FY 1999-2000) or
paid the Fire Assessment (enacted from FY 2000-2001 through FY 2006-2007) (referred to as
the "Class"). The Class is represented by Richard L. Williams, Esq., Michael Garcia -Petit,
Esq., and Patrick A. Scott, Esq (referred to as "Class Counsel"). In these lawsuits, the Class
challenges the legality of the City's Fire/Rescue Assessment and Fire Assessment (referred to
as the "Assessments"), on two bases. The first basis, referred to as the "refund portion,"
challenges the Assessments to the extent that monies were collected and allocated to "rescue"
or "EMS" services, and seeks a "refund" of all alleged illegally collected assessments. By law,
the Class is only entitled to a refund of money collected and allocated to EMS or rescue
services; the Class is not entitled to a refund of any money collected and allocated to fire
services. The second basis, referred to as the "apportionment portion," seeks a determination
that the Assessments were not properly apportioned among various categories of property
owners. The current Third Amended Complaint challenges the validity of the Fire/Rescue
Assessment and the Fire Assessment for all 10 years they were enacted.
There are also seven appeals, which were consolidated, pending before the Third
District Court of Appeal. The primary issue on appeal is whether the trial court's March 17,
2006 Order, which granted the Class and City's Motions to Set Aside the May, 2004,
settlement with the Original Plaintiffs (Nagymihaly), should be affirmed. All claims on
appeal, and all current or potential Class or City claims against the Original Plaintiffs
(Nagymihaly) their lawyers, or others, are not part of this settlement.
The Class and Class Counsel have presented the City with an offer to settle all currently
pending class action cases, encompassing all current or potential claims for all 10 claimed
fiscal years, on behalf of all Class members, for $15,550,000. The settlement amount is
inclusive of Class Counsel attorneys' fees, costs and all administrative costs. The Settlement
Agreement and Release contains all of the terms and conditions of the settlement. It was
drafted by Class Counsel and the City's Counsel, with the input of various experts, and the
independent Third Party Administrator.
83211 Page 2 of 8
It is recommended that the proposed Settlement Agreement and Release in the amount
of $15,550,000, be approved by this Commission for several reasons. First, the settlement
amount is a fair and reasonable compromise of competing claims between the Class and the
City. Second, the settlement is fair and reasonable under the law, the prior rulings of the
Florida Supreme Court and the trial court's orders in this case. Third, each of the parties has
conducted substantial investigation, and recognizes that the issues presented are unlikely to be
resolved without further extensive and costly litigation, and that such litigation will cause
inconvenience, distraction, disruption, delay and expense disproportionate to the potential
benefits of continued litigation. Each of the parties has taken into account the risk and
uncertainty inherent in any litigation. Each also recognizes that the Class is made up of the
City's taxpayers who, in a manner of speaking, sue themselves. Finally, the proposed
settlement will encompass as many property owners as possible. If the litigation were to
continue, and the trial court were to rule in favor of the City on some of its claimed defenses,
some of the Class members may not be entitled to a refund.
For these reasons, and for the reasons more fully set forth in the Settlement Agreement
and Release, it is recommended that the City Commission approve the settlement. The terms
and conditions of the proposed Settlement Agreement and Release agreement are summarized
in the attached Exhibit "A."
83211 Page 3 of 8
EXHIBIT "A"
MASZTAL PROPOSED SETTLEMENT KEY POINTS:
OFFER
Total Amount
$15,550,000
Class Attorneys' Fees
Attorneys' fees will be paid from $15,550,000 (the
"Common Fund").
Amount of Class
Attorneys' Fees
The amount of Class Attorney' fees will be determined
solely by the court.
Status of Disgorged Fees
Collected from Original
Plaintiffs
Any disgorged funds will revert to City, for benefit of
the Fire Department (if the City prevails in the pending
appeals).
Administrative Fees
To be deducted from the $15,550,000 Common Fund
after approval by the court.
Appeals
Pending appeals with Original Plaintiffs remain;
settlement has no effect.
Effect on Future
Assessment(s)
None.
Unclaimed Money
Remaining in Common
Fund
Any remaining unclaimed money after all valid refunds
are paid will revert to City for the benefit of the Fire
Department.
A summary of additional and essential terms are set forth below. The complete terms are
contained in the Settlement Agreement and Release:
1. This $15,550,000 settlement would be a settlement of all class claims in Masztal et al.
v. City of Miami, Case No. 98-11208 CA 31, all class claims in Masztal et al. v. City of
Miami, Case No. 05-2117 CA 31, and any and all claims that the class had, has, or may
have against the City arising out of the Fire/Rescue Assessment (enacted from 1997-
1998 through 1999-2000) or Fire Assessment (enacted from 2000-2001 through 2006-
2007). The settlement amount is a compromise of what the Class and the City believe
should be refunded by the City. However, given the costs, risks and uncertainties of
litigation, and the delay that will necessarily result if the claims are not settled, both
parties believe the settlement is fair and equitable to the class and to the City,
2. Class Counsel and counsel for the City, with input from various experts and the
independent third party administrator, worked together to ensure the settlement terms
are fair and equitable.
3. The settlement will be administered by an independent third party administrator,
mutually agreed to by all counsel. The administrative process includes providing
notice to the class, verifying the claims, and issuing the refund checks. The Parties will
cooperate in any manner requested by the administrator to provide the necessary
information to process and confirm all claims made.
83211 Page 4 of 8
4. if the settlement is approved by the City Commission, it must then be approved by the
court, per Florida law. A fairness hearing will occur where the court will rule on the
fairness of the settlement.
5. The class is seeking judgment ordering the City to refund the Assessments collected.
However, the amount of the refund owed, if any, has never been determined by any
court. There is a dispute between counsel for the City and Class Counsel as to that
amount. As a consequence of this settlement, the court will not determine the amount
of the refunds. The court has only determined that the rescue portion of the fire/rescue
assessment, from 1997-1998 through 1999-2000, was illegal. In the litigation, it is the
City's position that money collected from 1997-1998 through 1999-2000 that was
allocated to fire services and not rescue services was legally collected, and should not
be refunded. It is also the City's position that the amended fire assessment, beginning
in fiscal year 2000-2001 and currently in place, is a legal and constitutional assessment
per the Florida Supreme Court. Thus, money collected from 2000-2001 through 2006-
2007 should also not be refunded. Finally, it is the City's position that the .statute of
limitations bars any refund claims for fiscal years 1999-2000 through 2001-2002, and
some other claims for fiscal years 1999-2000 through 2006-2007. The class disagrees
with some of the claims set forth in this paragraph. Such disagreement would require
extensive litigation and rulings from the court. Moreover, because of the uncertainties
in any litigation, and the additional 'attorneys' fees, costs and time necessary to litigate
these and other issues in court, the proposed settlement is for the entire case and shall
encompass all fiscal years (1997-1998 through 2006-2007) and all claims alleged in the
Third Amended Complaint.
6. Each Class member who does not opt out of the Class, and timely sends in the
appropriate request for refund form, will receive a refund consisting of a percentage of
the Fire/Rescue and Fire Assessments that they were billed and that they paid.
7. We cannot currently determine what percentage of the Assessments collected will be
refunded to each property owner, because several variables exist, which are explained
below. However, no refund will be in excess of the amount that a property owner
actually paid in Assessments.
8. First, the exact amount of money that will be available for refunds is not currently
known. After the City transfers the $15,550,000 Common Fund to the independent
third party administrator, the money will be put into an interest bearing account. Any
interest accrued will be added to the Common Fund for the benefit of the Class. This
will increase the funds available to the Class. Second, Class Counsel's attorneys' fees
and costs, and the administrative costs, have not yet been determined. These amounts
will be determined and approved by the court. Once the court determines these
amounts, they will be subtracted from the common fund. Therefore, we cannot
currently determine the exact amount of money that will be available for distribution to
the Class. The refund percentage will also be affected by the number of Class members
who decide to make a valid claim. Some Class members may choose to opt out of the
Class, as is their legal right. Some may not send in the request for refund forms, not
send them in timely, or not send them in with the information required. Those who
timely send in the forms with the required information will remain in the Class and
their claim will be processed. The refund percentage will therefore also be affected by
the number of Class members who present a valid claim.
83211 Page 5 of 8
9. The priority of distribution of the funds shall be, as is typical of class settlements, as
follows: (a) the first priority shall be payment of Class Counsel's attorneys' fees and
costs, as determined by the court; (b) the second priority shall be payment of
administrative costs and expenses, as approved by the court; (c) the third priority shall
be payment of valid refund claims;, and (d) the fourth priority shall be reversion of any
remaining money back to the City. As aforementioned, the court will determine the
attorneys' fees and costs and administrative costs first, before the exact amount
available for Class claims is ascertained. If there is any money left in the Common
Fund, that money will go back to the City's general fund solely for the use and benefit
of the Fire Department.
10. If the settlement is approved by the City Commission, and the court, the City and all of
its current and former officers, officials, agents, representatives, and employees will be
fully released. However, the law allows any Class member to opt of the settlement and
continue its individual claim against the City. We cannot predict if this will occur.
11. This settlement does not preclude the Class or the City from bringing additional claims
against any other persons or entities who are not part of the Settlement Agreement and
Release.
12. There remain 7 different claims on appeal, all of which arise out of the previous
settlement. No opinion has been issued as of July 16, 2007. The appellate court's
ruling on the previous settlement will not affect this settlement with the Class. If the
Class and the City are successful on appeal, and the trial court's order setting aside the
prior settlement is upheld, all disgorged funds and any additional funds collected will
revert to the City, solely for the use and benefit of the Fire Department. If the appellate
court overturns the trial court's order setting aside the prior settlement, the City will
have to return the disgorged funds, cease current collection efforts against the Original
Plaintiffs, and make the additional $3,500,000 payment which was not made in
December, 2005.
13. If the Commission approves the proposed Settlement Agreement and Release, the
following is an estimated timeline of how the case will proceed:
(A) The settlement agreement will be signed by all the parties. Within 15 days
of execution of the agreement, the parties will move for preliminary approval of
the settlement from the court. Within that same 15 days, Class Counsel will
also change the definition of the Class members (to include all 10 fiscal years),.
file their petition for attorney's fees and costs, and the administrator will file its
estimated costs of administration.
(B) Once preliminary approval is granted by the court, the class notice period
will commence. The administrator will send out notice to every identified class
member. In addition, at least 5 separate notices will also be published in The
Miami Herald, El Nuevo Herald, and USA Today. The class notice period will
last 30 days. A web site will be set up so the class members can obtain answers
to fundamental questions. The administrator will also be available by toll -free
telephone to answer questions. The Administrator may request that the City
advance a portion of the Common Fund in an amount not to exceed $200,000,
in order to cover the costs of postage, mailing and publication during the period
of time prior to the fairness hearing. See Exhibit "B".
83211 Page 6 of 8
(C) The court will then set a date for a fairness hearing. Any Class members
who opt out of the settlement, or any who stay in but object to any terms of the
settlement, must do so by filing proper notice 15 days before the fairness
hearing.
(D) If the court approves the settlement after the fairness hearing, the City will
immediately transfer the settlement amount to the administrator, to be placed in
an interest bearing account. The administrator may ask the City to advance
some of the costs of the claims administration (such as postage, mailing and
publication) prior to final approval. If the City does this, that money will be
credited against the Common Fund.
(E) After court approval, the Class members will then have 30 days from the
date of approval to mail in the request for refund forms. The administrator will
process the forms, ensure the Class member is entitled to a refund, determine
the amount, and mail out a check. The administrator has 90 days from, the date
the request for refund forms are due to process the claims. If the administrator
deems a class member's request invalid for any reason, the Class member has
15 days from the date the form is rejected to re -submit the claim.
(F) Refund checks will be good for 180 days.
(G) The administrator will file a report with the court showing the number of
checks issued and the value of the claims made 20 days after the time period to
issue refund checks closes.
(H) Final Judgment should be entered by the court. The court will retain
jurisdiction to enforce the terms of the settlement.
14. Section III of the Settlement Agreement and Release allows the parties to ask the court
to alter any of the provisions or time deadlines relating to notice, opt out or objection, if
necessary. Any reasonable alteration will not nullify the agreement or settlement.
15. All pertinent forms, notices and the web site will be in English, Spanish and Creole,
and any other language deemed appropriate by the court, so all potential class members
can review these documents in one of several languages.
16. When the settlement is presented to the Commission for approval on July 26, 2007,
outside counsel for the City, Class Counsel and a representative of the independent
third party administrator will be present to answer any questions from the public or the
City Commission. If the City Commission or the court disapproves the settlement for
any reason, the parties will resume the litigation as if this proposed settlement never
occurred. No party will be deemed to have waived any claims or defenses if the
settlement is not approved.
Attachment(s)
cc: Pedro G. Hernandez, City Manager
Elvi Gallastegui, Agenda Coordinator
83211 Page 7of8
EXHIBIT "13"
ESTIMATED PRELIMINARY COSTS ASSOCIATED WITH NOTICE AND PUBLICATION
Item
Cost
Print/Mail 8-Image Notice and Request for Rebate
$ 25,000
Insertion into USA Today
$ 75,000
5 Insertions in Miami Herald and El Nuevo Herald
$ 35,000
Translation Expenses
$ 2,000
Website and VRU Setup (Multilingual)
$ 4,500
Postage
$ 75,000
$216,500
83211 Page 8 of 8