HomeMy WebLinkAboutSubmittal-Appellant's MemorandumfCITY COMMISSION OF THE
CITY OF MIAMI, FLORIDA
CASE NO. 2004-01208
5101 Biscayne Boulevard
APPEAL OF CLASS II SPECIAL
PERMIT
MORNINGSIDE CIVIC ASSOCIATION, INC., et al.,
Petitioners,
vs.
CITY OF MIAMI ZONING BOARD, et al.,
Respondents.
SUBMITTED INTO THE
PUBLIC RECORD FOR
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APPELLANTS' MEMORANDUM
The MORNINGSIDE CIVIC ASSOCIATION, INC., ROD ALONSO,
ROB STEBBINS, SCOTT CRAWFORD, by and through undersigned counsel
(and ELVIS CRUZ, pro se), file this Memorandum in support of their appeal of
the Zoning Board's decision to issue a Class II Special Permit for 5101 Biscayne
Boulevard. For the reasons that follow, the appeal should be granted and the
permit should be denied or this matter must be remanded to the Zoning Board for
consideration of the appeal.
Procedural Background and Standard for Review
The procedural background of this case is lengthy and complicated, but
the relevant elements are set forth briefly here. On November 20, 2003 the
off- o/2ogQ- Subm, it2j_ Opp k Mevrloraridur,-)
Zoning Administrator determined that the project complied with the
requirements of the Zoning Code and the project was forwarded to the Planning
Depaitnient, which ultimately granted a Class II Special Permit. The City of
Miami does not send or publish notice to the public about the Zoning
Administrator's determinations. (Transcript of Appeal Hearing, May 27, 2010,
page 110, copy attached hereto.) The first time the determinations of the Zoning
Administrator that lead to the grant of a Class II Special Permit are made public
is when the Planning Department issues its final decision. In this case, that
occurred on July 21, 2004 (copy attached). Because the Zoning Administrator's
determination that the project complied with the setback requirements of the
Zoning Code was erroneous, Appellants promptly filed an appeal to the Zoning
Board, as provided for by Section 1806 of the Zoning Ordinance, which states
that:
"The zoning board shall conduct the public hearing on the appeal....
"New materials may be received by the zoning board where such materials are
pertinent to the determination of the appeal."
On October 4, 2004 appellants appeared before the Zoning Board to
contest the finding that the project conformed to the Zoning Code. Developer's
counsel immediately objected and moved to dismiss the appeal on the basis that
it was untimely and should have been made at the time of the Zoning
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Administrator's original determination, even though appellants admittedly had
no notice of that decision or any opportunity to be heard. The Zoning Board
granted this oral motion to dismiss, and refused to consider appellants'
arguments that the project did not comply with the Zoning Code on the basis that
they failed to timely appeal the Zoning Administrator's decision, a decision that
they were never made aware of in the first instance.
Thereafter, appellants appealed to the City Commission, which granted
their appeal. The Circuit Court upheld the City Commission's decision, and the
developer appealed to the Third District Court of Appeal. The Third District has
remanded this matter for an appellate determination in accordance with the
Circuit Appeals Court's July 14, 2006 opinion rather than a de novo review.
(See attached July 14, 2006 Circuit Court opinion). In that opinion, the Circuit
Court was critical of the Commission's decision in two respects: 1) that no
written findings were made in accordance with Section 1305, and 2) that a de
novo review was conducted. Thus, the Commission's appellate review of the
Zoning Board's determination is limited to determining: (1) whether procedural
due process was accorded, (2) whether the essential requirements of the law have
been observed, and (3) whether the administrative findings and judgment are
supported by competent substantial evidence. Dusseau v. Metropolitan Dade
County Board of County Commissioners, 794 So. 2d 1270 (Fla. 2001).
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The Permit Does Not Conform to the Essential Requirements of Law
In a zoning decision, complying with the clear requirements of the Zoning
Code is paramount. It is a pure question of law and appropriate for the
Commission to consider on appeal of the ZB's determination. In this case, there
are three separate violations of the setback requirements on the face of the permit
granted. Section 401 of the Zoning Code, as it existed at the time of the original
decision, required a minimum front setback of 20 feet, and a minimum rear
setback of 20 feet when the project abuts a single family neighborhood. The site
plan of this project has a 15 foot front setback along Biscayne Boulevard and
only a 10 foot rear setback where it abuts the single family neighborhood of
Morningside. Although the developer attempted to label a side with no front
door to be the "front" of the building to skirt the setback requirements, it is
apparent from the site plan that the front of the building is situated facing the
major corridor of Biscayne Boulevard, and this is the requirement of the Zoning
Code. Section 907.3.1 requires that the "most restrictive condition" applies
where two differing zoning designations abut each other.
There is a third obvious Zoning Code setback violation — this time of
Section 907.3.2, which requires a 2 to 1 sloping vertical rear setback starting at
40 feet, for any building which abuts a single family district. Appellants attach
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hereto for your convenience pictures of the plans with highlighted demarcation
of the required setbacks to which the project has not adhered.
Perhaps most importantly, the applicant's and the city's argument at the
Zoning Board was based on a physical impossibility. At the Zoning Board
hearing of October 4, 2004, the applicant argued, and city staff concurred, that
the building plans were reviewed and found to be in compliance with all zoning
requirements by the Zoning Administrator on November 20, 2003, and if the
appellants disagreed they should have appealed at that time. However, the plans
before the Zoning Board, which were approved by the Planning Director for a
Class 2 permit, are dated June 30, 2004 — more than seven months later, after
they were substantially modified, as both the applicant and the city stated at the
Zoning Board hearing. It is therefore physically impossible for the Zoning
Administrator to have approved these plans, for the simple reason that they did
not even exist on November 20, 2003, and would not exist until seven months
later. Therefore, the Zoning Board made its decision to grant this permit based
on evidence that was not competent and substantial. Furthermore, that evidence
included three departures from essential requirements of law, therefore, that
decision must be reversed, the appeal upheld, and the permit denied.
Moreover, the Zoning Board departed from the essential requirements of
law where it approved a project without any rear setback where the code clearly
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contemplates: side, rear, and front setbacks. There must be a rear of the project
somewhere and yet the Zoning Board approved plans with (3) three "fronts" and
(1) one "side". We can speculate that the reason why the Developer never
designated a rear on the plans is that they knew they would have to have a 20
foot setback, but even without speculation as to the Developer's motive, the fact
is that there is no rear side shown for this project on the architectural plans
reviewed by the Board.
Lastly, the Zoning Board never made the written findings of fact under
Section 1305 (2003 version). The Circuit Court in 2006 specifically held that
this was required, and appellate decision, for better or worse, has become the
"law of the case". Accordingly, the Zoning Board departed from the essential
requirements of law in this respect as well, and the case should be remanded to
that body for the required findings.
The Zoning Board did not Afford Appellants Procedural Due Process
As set forth above, it is uncontested in this matter that the Zoning Board
did not permit appellants to challenge the underlying determination of the
Zoning Administrator that the project conformed to the Zoning Code, nor is it
contested that the appellants received no notice or opportunity to be heard when
the Zoning Administrator made his decision.
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To the extent that the City's own code and rules permitted or required (as
the city argued) this procedural result, those provisions violate due process
requirements. Section 1801 states:
Sec. 1801. - Status of administrative decision; time limits on appeal; filing of
appeal.
Decisions of the zoning administrator or the director of the department of
planning, building and zoning shall be deemed final, unless a notice of appeal is
filed within not more than fifteen (15) calendar days of the date such decision
was rendered. Such notice of appeal, specifying the grounds thereof shall be
filed with an officer or agent designated by the city manager.
However, "In quasi-judicial zoning proceedings, the parties must be able
to present evidence and cross-examine witnesses." Jennings v. Dade County, 589
So.2d 1337, 1340 (3rd DCA 1991) (emphasis supplied). The opportunity to be
heard must be meaningful, full and fair, and not merely colorable or illusive.
Metropolitan Dade County v. Sokolowski, 439 So.2d 932, 934 (3rd DCA 1983).
Because of the Court's order quashing the City Commission's customary de
novo review of Class II Special Permit appeals, the Zoning Board hearing is the
only opportunity that appellants have for a full and fair public hearing on this
matter. Prohibiting the appellants from introducing any argument or evidence in
support of their appeal in this matter violated these fundamental due process
principles.
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Furthermore, the Zoning Board's failure to afford appellants a full and fair
de novo hearing before the Zoning Board departed from the essential
requirements of law. Section 1806 of the Zoning Ordinance clearly states that:
"The zoning board shall conduct the public hearing on the appeal....
"New materials may be received by the zoning board where such materials are
pertinent to the determination of the appeal."
Finally, the Zoning Board follows Robert's Rules of Order. This is
significant for the following reason: On the day of the hearing, the appeal was
dismissed and not considered because the applicant's attorney interrupted
appellant's argument and initiated an oral Motion to Dismiss. Strangely enough,
the chair and the city attorney allowed the motion to dismiss to be heard and
granted, even though the concept of a "Motion to Dismiss" does not exist in
Robert's Rules of Order. This was a separate and further failure of due process.
For the foregoing reasons, the permit should be denied, or, in the
alternative, this matter should be remanded to the Zoning Board with instructions
to conduct a full and fair de novo hearing.
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Respectfully Submitted,
‘R &Zia
LUIS FERNANDEZ
Attorney for Morningside Civic Association, Inc., et al
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was hand
delivered and emailed this 13th day of November, 2012, to: SUSAN E.
TRENCH, ESQ., Arnstein & Lehr, P.A., 200 S. Biscayne Boulevard, Suite 3600,
Miami, FL 33131 (setrench@arnstein.com); and JOHN A. GRECO, ESQ.,
Office of the Miami City Attorney, 444 SW 2 Ave., Suite 945, Miami, FL,
33136, and email (JAGreco@miamigov.com).
By:
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Ake 9bat2
LUIS FERNANDEZ
Fla. Bar No. 0271578
2250 SW 3 Avenue, Suite 303
Miami, FL 33129
(305) 854-5955
(305) 854-5324
LFernandezlaw@aol.com
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City Commission Meeting Minutes May 27, 2010
that decision, if there was an issue about what the zoning -- whether or not this --
Chair Sarnoff: All right. Just stay right there for a minute. Does Morningside get notice of the
Zoning administrator's decision?
Ms. Dougherty: Not at that time, no.
Chair Sarnoff Well --1 mean, this board has done this many times. And I know Commissioner
Suarez has brought this up. How are you supposed to appeal something when you don't know
the results of the findings and conclusions? Any rate, as long as it's clear that he could not and
did not know about the Zoning administrator --
Ms. Dougherty: He could have known. He didn't know --1 mean, 1 don't know if he could or
didn't know.
Chair Sarnoff Did we publish it? Do we get it out there? Do we put people --
Ms. Dougherty: No.
Chair Sarnoff -- on notice?
Ms. Dougherty: I have no idea whether --
Chair Sarnoff I'm sure you would —
Ms. Dougherty: -- they knew or didn't.
Chair Sarnoff -- concede with me that notice is a primary procedural requirement of any due
process argument that anybody can make. Whether you get substantive due process, you must
have notice and the opportunity in which to address the substance.
Ms. Dougherty: If I may?
Chair Sarnoff: Do you agree with that?
Ms. Dougherty: The -- in the general terms, yes -- the appellant, the appeal that he made says
Section 7 -- 907.3.2 of the City's zoning ordinance requires additional setbacks for projects built
higher than 40 feet when abutting a residential zoning district in the rear. This does not abut a
zoning district in the rear. In other words, this is a project between 51 s1 and 52nd on Biscayne
Boulevard, and your Zoning Code has a definition at that time for the front yard. The front yard
is the smallest zoning -- the smallest lot line in the project -- in the lot, so that is not a rear yard.
There is no rear yard. In fact, the Zoning administrator for years have determined that there is
no rear yard when you're on three streets. So this is not a rear of a zoning district and,
therefore, it is not applicable.
Chair Sarnoff.• 1--
Unidentified Speaker: (UNINTELLIGIBLE) setback from the plans themselves.
Ms. Dougherty: Those plans, themselves, that they determine --
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Mr. Sastre: What did they apply? record in connection with
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Ms. Dougherty: -- that they're showing, it says —
Dwight S. Danie
City Clerk
City of Miami Page 110 Printed on 8/24/2010
CITY OF MIAMI
CLASS II SPECIAL PERMIT
FINAL DECISION
File No. 03-0309
To:
From:
Lucia A. Dougherty, Esq.
c/o Greenberg Traurig
1221 Brickell Ave
Miami, FL. 33131
Ana Gelabert, Director
Planning and Zoning Department
PLEASE TAKE NOTICE THAT A INTENDED DECISION HAS BEEN REACHED ON THE FOLLOWING MATTER:
Title: New Construction (5101 Biscayne Blvd)
Address: 5101 Biscayne Blvd., Upper Eastside
Final Decision:
❑ Approval
El Approval with conditions
❑ Denial
FINDINGS AND CONDITIONS
The subject proposal has been reviewed for Class II Special Permit pursuant to Article 15, Section
609.3, 1512 and 923.2 of Ordinance 11000, as amended, the Zoning Ordinance of the City of Miami,
Florida. Section 609.3 states explicitly that a Class II Special Permit shall be required prior to approval
of any permit affecting the location, relocation or alteration of any structure, sign, awning, landscaping,
parking, area or vehicular way visible from a public street. Section 1512 states that unless otherwise
required by the Zoning Ordinance, as amended, the Code of the City of Miami, as amended or the
South Florida Building Code, as amended, all City of Miami Design Standards and Guidelines,
incorporated herein by reference, may be waived pursuant to a Class II Special Permit. Section 923.2.1
states that reduction in loading stalls shall be only by Class II Special Permit.
Pursuant to Section 1301.2. of the above cited Zoning Ordinance, the Planning and Zoning
Department has made referrals to the following Departments and Boards.
• Zoning Division, Planning and Zoning Department.
• Upper Eastside NET Office, Neighborhood Enhancement Team.
• UDRB, Urban Development Review Board.
Their comments and recommendations have been duly considered and are reflected in this intended
decision. In reviewing this application, pursuant to Section 1305 of the Zoning Ordinance, the following
findings have been made:
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FINDINGS
• It is found that the proposed project is a mixed -use building consisting of residential units (89) and
common areas (4,799) sq.ft with parking garage.
• It is found that the proposed project was initially reviewed by the Internal Design Review
Committee on November 25, 2003. The committee recommended sending it back to the architect
in order to give the opportunity to respond to the committee comments.
• It is found that a modified project was reviewed by the Design Review Committee on January 13,
2004 but the original comments are still pending and have not been resolve.
• It is found that an Intended Decision was issue on March 25, 2004.
• It is found that a modified project that included the modifications recommended by the Internal
Design Review Committee was reviewed by the committee on May 4 and May 18, 2004; finally, on
July 6, 2004, the committee reviewed and approved with conditions the subject proposal.
• It is found that the landscape plan submitted with this application complies with the Miami -Dade
Landscape Ordinance.
• On January 21, 2004 the Urban Development Review Board reviewed and deferred for the next
meeting the subject proposal.
• On March 17, 2004 the Urban Review Board reviewed and approved with conditions the subject
proposal.
• It is found that with regard to the criteria set forth in Sec. 1305 of the City of Miami Zoning
Ordinance, the application has been reviewed and found sufficient except for the issues listed
above and contained in the conditions.
Based on the above findings and the considered advice of the officers and agencies consulted on this
matter and pursuant to Section 1306 of the Zoning Ordinance, the subject proposal is hereby
approved with conditions as presented in the plans and supporting materials submitted by the
applicant and on file with the Department of Planning and Development and further subject to the
following conditions:
1 The applicant shall comply with the conditions addressed by the UDRB and the Internal Design
Review Committee.
2. New plans shall be submitted to the Planning and Zoning Department for review and approval
before issuance of any budding permit.
NOTICE
The final decision of the Director may be appealed to the Zoning Board by any aggrieved party,
within fifteen (15) days of the date of issuance by filing a written appeal and appropriate fee
with the Office of Hearing Boards, located at 444 S.W. 2nd Avenue, 7`h Floor, Miami, FI. 33139.
Telephone number (305) 416-2030.
Signature
Ana'G labert; ivector
Planning and Zoning Department
2
Date
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NOT FINAL UNTIL TIME EXPIRES
TO FILE RE -HEARING MOTION
AND, IF FILED, DISPOSED OF
LUCIA DOUGHERTY, on behalf of
Contract vendee, J. Laurence Eisenberg,
Trustee
v.
J U L i Lt aue'•6
HARVEY RUVIN
CLERK
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI DADE
COUNTY, FLORIDA
Petitioner,.- ------------APPELI AgHCASE-NO:-05s409 AP -
CITY OF MIAMI, FLORIDA,
a Florida municipal corporation,
MORNINGSIDE CIVIC ASSOCIATION,
INC., a Florida corporation, ROD ALONSO,
RON STEBBINS, SCOTT CRAWFORD and
ELVIS CRUZ,
Respondents.
Amended opinion filed this
LOWER CASE NO. R040764
, 2006.
An appeal from the City of Miami Commission.
Susan Trench, Esq., for the Petitioner.
Michael A. Sastre, Esq., for the Respondents.
Jorge L. Fernandez, Esq., Office of the City Attorney, for the City of Miami, Florida.
Before FERNANDEZ, SCHWARTZ, and PEREYRA-SHUMINER, JJ.
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App. 53
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FERNANDEZ, Judge.
Having thoroughly reviewed the pleadings and papers in this case, the ruling of
the City of Miami Commission should be reversed and remanded.
Lucia A. Dougherty, is the Petitioner and the zoning applicant on behalf of the
record title owner, Chetbro, Ltd. Momingside Development LLC is the project
developer. The subject property is located at 5101 Biscayne Boulevard in Miami,
Florida. The proposed development is regulated by Section 609 of the City of Miami
Zoning Code, SD-9 Biscayne Boulevard North Overlay District Regulations. In
accordance with the requirements of the SD-9 Regulations, the Petitioner applied for a
C ass II Special Permit: -The -proposed development would be ainfixed-use-project;
consisting of residential units with retail space on the ground floor. On November 20,
2003, the Petitioner's application was referred to the City of Miami Zoning Department
for review of the Class II Special Permit.
On April 29, 2004, the first amendment to the SD-9 Regulations was adopted
imposing a ninety-five (95) foot height restriction on construction for new residential
projects located in the district. This amendment to Zoning Ordinance 11000 became
effective thirty days after adoption. On July 21, 2004, the City of Miami Zoning
Department issued a final decision approving the Class II Special Permit for the proposed
development subject to conditions. The conditions required the Petitioner to revise its
plans and incorporate design modifications recommended by the City of Miami Planning
and Zoning Department. A day later, on July 22, 2004, the Commission passed on its
first reading the second amendment to the SD-9 Regulations, mandating a twenty-five
(25) foot height limitation on rear setback structures, such as garages abutting a
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residential zoned area. This specific height restriction applied to properties over 150 feet
in depth as of April 29, 2004.
On August 23, 2004, the Petitioner filed its completed application, which included
additional height modifications in compliance with the first amendment. The second
amendment was adopted on its second and final reading held on September 27, 2004. On
October 27, IOW, the Petitioner was granted the Class II Special Permit. The
Respondent, Momingside Civic Association appealed the issuance of the permit to the
City of Miami Zoning Board. On December 13, 2004, the Zoning Board affirmed the
issuance of' the special permit. Thereafter, Respondent, Momingside Civic Association
appealed the decision of the Zoning Board to the City of Miami Commission (hereinafter
"Commission.").
On September 23, 2005, the Commission convened a hearing on the subject
appeal. At this hearing, the Commission heard testimony constituting new evidence
which was not presented to the Zoning Board. Without making specific written findings,
the Commission issued a general statement that "the Class II Special permit does not
meet the applicable requirements of Zoning Ordinance No. 11000, as amended." As
such, the Commission reversed the decision of the Zoning Board. Based on this ruling,
the Petitioner filed its petition for writ of certiorari requesting that the appellate court
quash the decision of the Commission.
As a preliminary matter, the Court addresses the issue of standing raised by the
Respondent. Pursuant to Section 2005 of the Miami Zoning Ordinance "an appeal may
be taken by any person or persons, jointly or severally, aggrieved by any decision of the
City Commission." Similarly, Section 163.3215, Fla. Stat. (2004) sets forth a liberalized
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standing requirement to "allow an adversely affected third party to maintain an action."
Payne v. City of Miami, 2005 WL 3054601 (Fla. 3rd DCA 2005). Case law precedent
clearly establishes that an adversely affected party includes the "owner, developer, or
applicant for development order." Id. This Court finds that the Petitioner, as applicant,
possesses the requisite standing to assert this claim pending before the Court. Further,
the Court finds that the record title owner to the subject property remains unchanged from
the zoning application originally filed.
Florida courts have established the standards for review of local agency action on
the first -tier, circuit court level. On appeal, the circuit court must determine: (1) whether
procedural due process is accorded; (2) whether the essential requirements of the law
have been observed; and (3) whether the administrative findings and judgment are
supported by competent substantial evidence. Broward County v. G. B. V. International,
Ltd., 787 So. 2d 838 (Fla. 2001), Haines City Community Development v. Heggs, 658
So. 2d 523 (Fla. 1995).
In the instant case, the Commission did not make specific findings of fact.
Florida case law does not require specific findings of fact provided that the ruling is
supported by competent substantial evidence. Bell South Mobility, Inc. v. Miami -Dade
County, 153 F. Supp. 2d 1345 (Fla. USDC So. Dist. 2001), Board of County
Commissioners of Brevard County v. Snyder, 627 So. 2d 469 (Fla. 1993). However,
the City of Miami Zoning Code imposes certain standards.
Section 1305 of the City of Miami Zoning Code expressly provides that:
City agents, agencies, or boards charged with decisions concerning special
permits shall make, or cause to be made, written findings and determinations
concerning such of the following matters as are applicable in the case, shall
reflect such considerations and standards specifically in the record...
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App. 56
Based on Section 1305, the City Commission was mandated to include in their ruling
written findings which specifically set forth the considerations and standards that are
supported by substantial competent evident e. The City Commission failed to comply
Wl
, asing its ruling on a general statement. The critical reason for
requiring an administrative agency to state their conclusions and orders with specificity is
to facilitate judicial review and bolster decisions. City of Winter Park v. Metropolitan
Planning Organization for the Orlando Urban Area, 765 So. 2d 797 (Fla. 1st DCA 2000).
The City is bound by the procedural requirements imposed by the code and cannot renege
on its promise to its citizens to uphold the code. Gulf & Eastern Development
-Cura on v.-CO—of Fort Laudeidale; 3"54"So-2d 57 (Fla. 19781 "Failure of an agency"
to adhere to its oWn regulations constitutes a departure from the essential requirements of
the law. Rosa Hotel Developers, Inc. v. City of Delray Beach, 10 Fla. L. Weekly Supp.
600b (Fla. 15th Cir. Ct. 2003). As such, the ruling of the City Commission fails to
observe the essential requirements of the law, the second prong of first tier appellate
review.
A second issue in the case at bar ,concerns the admission of new evidence at the
hearing before the City Commission. The new evidence considered by the City
Commission was not presented to the Zoning Board. The traditional scope of appellate
review limits consideration of matters to materials available to the lower court or tribunal.
Fla. R. App. P. 9.190(c). Conducting a de novo hearing exceeds the authority of
appellate review. G. B. V. Intemational , Ltd., 787 So. 2d at 846.
Section 1201 of the City of Miami Zoning Ordinance provides that:
The City Commission shall have only the following duties: (4) Reviewing,
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upon request, decisions of the Zoning Board when it serves in an appellate
capacity with respect to decisions of ...the director of planning, building and
zoning. (Emphasis added)
The usa
imp s t e scope of "review" in an appellate capacity. By
comparison, Section 1305 of the City of Miami Zoning Ordinance, expressly provides
that "new materials may be provided by the Zoning Board where such materials are
pertinent to the determination of the appeal." This express provision empowers the
Zoning Board to receive new materials. There is no similar provision for the City
Commission to receive new evidence. Accordingly, the City Commission was limited to
review of the record received from the Zoning Board. The nature of inquiry narrows as
the case proceeds up the judicial ladder. City of Deerfield Beach v. Valliant, 419 So. 2d
624 (Fla. 1982). By conducting its own de novo assessment, the City Commission
usurped the authority of the Zoning Board. G. B. V. Intemational Ltd., 787 So. 2d at
846. As such, by reversing the Zoning Board's issuance of the Special Permit, the City
Commission failed to follow the essential requirements of the law.
Based on the foregoing procedural errors, this matter is reversed and remanded
for further proceedings consistent with this opinion and with controlling case law set
forth in Momingside Civic Association v. City of Miami Commission, 917 So. 2d 293
(Fla. 3d DCA 2005).
COMES MASHED TO'' -
COUNSEL' E4. 01= RECORD AND
• MANY PARTY NOTREPRES
$Y COUNSEL ' —
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Mechanical
t
Common Areos
4.799 SF
BISCAYNE BOULEVARD
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NORTH ELEVATION
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2nd LOVOL
BISCAYNE BLVD o -o
Submitted into the public
record in connection with
items PZ.16 on 01-10-13
Dwight S. Danie
City Clerk