HomeMy WebLinkAboutSubmittal-Memo-Law-Miami River CasesCITY OF MIAMI
OFFICE OF THE CITY ATTORNEY
MEMORANDUM
TO: The Honorable Mayor and Members of the City Commission
FROM: Jorge L. Fernandez, City Attorney
DATE: September 17, 2007
SUBJECT: Herbert Payne, et. al. vs. City of Miami, et al.
Case No.: 3D06-2409 (Coastal on the River project)
Case No.: 3D06-2718 (Brisas del Rio project)
Case No.: 3D06-1799 (Hurricane Cove project)
RE: Miami River Cases
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As I reported to you earlier. the Third District Court of Appeal recently rendered an
appellate decision in the Balbino Investments, LLC case' (the "Hurricane Cove" decision),
reversing an order favorable to the City of Miami issued by an Administrative Law Judge
("ALJ") of the Division of Administrative Hearings ("DOAH") and the State of Florida
Department of Community Affairs ("DCA"). The case stemmed from the City of Miami's
approval of a small scale amendment to the Future Land Use Map ("FLUM Amendment") for a
7.91 acre parr -el located at 1818/1884 Northwest North River Drive, which changed the land use
designation o, the property from Industrial and. General Commercial to Restricted Commercial.
The Third District Court of Appeal reversed the ALJ/DOAH decision leaving the
property as if the resulting land use change had not occurred, that is, the Court's decision
invalidated the FLUM amendment and reinstated the property's former Industrial and General
Commercial designations. Despite the City of Miami's longstanding interpretation of the Port of
Miami River subelement that it applied only to specific shipping companies at certain locations
along the Miami River —the Appellate Court found that the Miami River subelement was
intended to protect or preserve any property along the Miami River classified or used as "marine
industrial." The Appellate Court additionally opined that the ALJ order was subject to reversal
for the following reasons:
• Failure to consider the FLUM amendment's impact upon fundamental Port of Miami
River decisions contained in the Comprehensive Plan and the Miami River Master Plan.
• FLUM amendment was inconsistent with both the Comprehensive Plan and the Miami
River Master Plan.
• That the entire City of Miami should not be an urban infill site that relaxed small scale
comprehensive plan amendment review, but that only targeted areas within the City of
Miami should be so designated.
• The SD 4 Special Zoning District entitled Waterfront Industrial District is undezinined by
this FLUM.
• The FLUM allows encroachment of non -water related or dependent uses that have no
relevance to nor do they support the maritime industry.
" Capt. Herbert Payne, Durham Park Neighborhood Association, Inc. & The Miami River Marine Group, Inc. vs.
City of Miami & Balbino Investments, LLC, (Hurricane Cove) No. 3D06-] 799 (Fla. 3`d DCA August 8, 2007).
Submitted into the public
record in connection with
item I'Z.1 on 05-08-08
Priscilla A. Thompson
City Clerk
Honorable Mayor and Members of the City Commission
Miami River Cases
September 17, 2007
• The FLUM ran afoul of the Coastal Management section of the Comprehensive Plan and
that the Future Land Use element of the comprehensive plan will not reduce industrial
noise and pollution or help a declining area as the ALJ found but rather will increase
traffic and hurt economic development.
• The City of Miami was losing marine and waterfront industrial properties through FLUM
amendments.
• The FLUM is inconsistent with the Miami River Master Plan.
In short, the Appellate Court decided the FLUM amendment was not consistent with the
City of Miami Adopted Comprehensive Plan at the Miami River Master Plan.
Both the City of Miami and Balbino Investments, LLC have timely served a Joint Motion
for Rehearing, Rehearing En Banc and/or Motion for Certification to the Florida Supreme Court.
We are arguing that the Appellate Court's en bane review is required to resolve a disputed
interpretation of the Port of Miami River subelement, and that the original Court of Appeal panel
gave an impermissibly broad and far-reaching definition to the Port of Miami River subelement
beyond the scope of the Comprehensive Plan and the legislative intent of the City of Miami
planners. We also argue that the original panel misinterpreted the Port of Miami River
Subelement and independently reweighed and reevaluated the evidence to reach the result it
desired, which was beyond its power as a reviewing Court. We further maintain that the original
appellate panel usurped the administrative agency's role by conducting a de novo hearing, that
is, the panel re -tried the case. More specifically, the appellate panel has departed from the
governing standard of review in how it addressed the issues of coastal management, future land
use, marine uses and the Miami River Master Plan. In brief, in arguing for a rehearing and
rehearing en bane, the Appellees argue that the original appellate panel exceeded its authority
and limitations in the scope of its review on appeal. The Appellees have further requested
certification to the Florida Supreme Court as a question of great public importance„
Even more recently, the Third District Court of Appeal decided the case of Payne, the Durham
Park Neighborhood Association, Inc. & The Miami River Marine Group, Inc. vs. City of Miami
and Riverside 22 Investments, LLC` ("Coastal on the River" decision), which essentially
duplicated the "Hurricane Cove" decision. The case stemmed from a property located at
2215 NW lot Streetin the Middle River area. The City of Miami approved a FLUM
amendment to change the land use designation from Industrial to Restricted Commercial. This
allowed the development of a multi -family development project on the property. The project
was to have consisted of 4.3 acres of a waterfront parcel for a twelve story residential
condominium. The Coastal on the River decision is very similar to the Hurricane Cove decision
discussed at length above. The appellate panel opinion again found that the ALJ/DOAH erred, in
failing to apply the appellate court's definition of the Port of Miami River, failed to consider the
Port of Miami River Subelement and critical areas of the Coastal Management and Future Land
Use element of the River Master Plan„ and made findings that were not supported by the
evidence. The appellate panel reversed a favorable ruling the City of Miami and Balbino
Investments, LLC had earlier obtained from the ALJ; that this PLUM amendment was consistent
with the City of Miami's adopted comprehensive Plan. This ruling is very recent, but insofar as it
appears to be a clone of the Hurricane Cove ruling, the City of Miami and Riverside 22
Payne, et. al. vs, City of Miami, et. al., (Coastal on the River) No. 3D06-2409 (Fla. 3rd DCA August 29, 2007)
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Submitted into the public
record in connection with
item 'Z.1 on 05-08-08
riscill;� A. Thompson
City Clerk
Honorable Mayor and Members of the City Commission
Miami River Cases
September 17, 2007
Investments, LLC again plan to file a -Motion for Rehearing, Rehearing en bane and Certification
of the Coastal on the River case to the Florida Supreme Court.
Lastly, the final related or connected case in this matter which is styled Payne, et. al. v.
City of Miami, et. al.' ("Brisas del Rio case") is set for oral argument on September 19, 2007.
This case involves property located at 1583 NW 24th Avenue. The City of Miami approved a
FLUM amendment for the property from Industrial and Medium Density Residential to
Restricted Commercial. The City of Miami won the administrative hearing before the ALJ and
the final order was accepted by DOAII. The Plaintiffs have filed an appeal before the Third
District Court of Appeal challenging the FLUM's consistency with the Comprehensive Plan on
much the same grounds. 1-he City of Miami and Brisas del Rio, LLC successfully maintained at
the administrative hearing its arguments that this FLUM was consistent with the comprehensive
plan.
Jurisdiction of the District Court of Appeal
Rehearing En Banc
This office has moved for a rehearing of the Hurricane Cove decision and plans to
move for a rehearing of the Coastal on the River decision on the same grounds. A motion for
rehearing may be filed within fifteen (15) days of an order.' A motion for a rehearing "shall
state with particularity the point of law or fact that the court has overlooked or misapprehended
in the decision." A party may move for an en banc rehearing "solely on the grounds that the
case is of exceptional importance or that such consideration is necessary to maintain
uniformity in the court's decisions."' All other grounds will be stricken. A vote on the motion
needs to be requested by a Judge on the panel that heard the proceeding.
A rehearing en banc is an extraordinary proceeding. The grounds must be clearly
established. The motion must contain either of these two statements:
"1 express a belief, based on a reasoned and studied professional judgment that the
panel decision is of exceptional importance." Or
"1 express a belief, based on a reasonable and studied professional judgment, that the
panel decision is contrary to the following decision(s) of this court and that a consideration by
the full court is necessary to maintain uniformity of decisions in this court (citing specifically
the case or cases)."
The jurisdiction of the Florida Supreme Court is limited. The discretionary jurisdiction
of the Supreme Court may be sought to review decisions of District Courts of Appeal that:
i. Expressly declare valid a state statute;
ii. Expressly construe a provision of the state or federal constitution;
i11, Expressly affect a class of constitutional or state officers;
iv. Expressly and directly conflict with a decision of another district court
or of the Supreme Court on the same question of law;
' Payne, et. al, vs. City of Miami, et. al., (Brisas del Rio) No. 3D06-GM-261(F1a. 3rd DCA 2006, pending).
Rule 9.330(a), Fla. R. App. P., (2006).
5 Rule 9.331(d), Fla. R. App. P., (2006).
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Honorable Mayor and Members of the City Commission
Miami River Cases
September 17, 2007
v. Pass upon a question certified to be of great public importance;
Ni. Are certified to be in direct conflict with decisions of other district
courts of appeal.
In the present situation, the City of Miami could try to obtain Supreme Court
jurisdiction by two (2) methods:
• As a certified question of great public importance, such as "Are long standing
interpretations of a City of Miarni's Comprehensive Plan entitled to the `fairly
debatable' standard of review?"
o The DCA would have to certify the question. This is the option we have
taken on the Hurricane Cove decision.
Another method that is sometimes available is:
• Challenging a decision that expressly and directly conflicts with a decision of
another DCA on the same question of law. See, St. Johns County v. Owings,
and Dixon v. City of Jacksonville. (We have not employed this option as of
this writing.)
o The DCA does not have to certify the matter but the issue must clearly
and directly conflict with another DCA.
We have discussed the legal measures we are undertaking and recommending relative
to these actions. A legislative measure would be to repeal or modify the Port of Miami River
subeternent in the City of Miami's adopted comprehensive plan. This is because it is an
optional element of the comprehensive plan as opposed to a required element (e.g. capital
improvements element, future land use element, traffic circulation element, sewer, solid waste,
drainage, potable water and natural groundwater element, conservation & housing element,
coastal management element, et. aL). §163.3177, Fla. Stat. As such it could be repealed or
amended as a text change to the Comprehensive Plan. § ] 63.3184, §163.3187, Fla. Stat.
Enclosure(s)
89743
Submitted into the public
record in connection with
item. PZ,l on 05-08-08
Priscilla A. Thompson
City Clerk
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