277316 WHITE - CITY CLERK (�y I�
PtNK • FINANCE ��_S�C
C/fN�ARY - DEPARTMENT G I TY O F SA I NT ��U L COIlAC1I t� V
BLUE - MAYOR
File N .
ncil Resolution
Presented By
Referred To Committee: Date
Out of Committee By Date
WHEREAS, The Council of the City of Saint Paul did issue a
Class B Restaurant License for premises located at 490 Summit
Avenue; and
WHEREAS, Karl Van D'Elden and others did file suit against
the City of Saint Paul on the grounds that the issuance of said
license was in violation of the 1975 Saint Paul Zoning Code and
the Summit Avenue Restricted Residence District; and
WHEREAS, These issues were tried before the Honorable Joseph
P. Summers, Judge of District Court; and
WHEREAS, Judge Summers found, among other things, that the
Restricted Residence District from Dale to the Cathedral to be
void and that the granting of a Class B Restaurant License for
490 Summit was continuation of a legal use under the 1922 Zoning
Code; and
WHEREAS, Judge Summers ordered Defendant City of 5aint Paul
to pay part of Plaintiffs ' attorney' s fees in the amount of
$25,000, for in the opinion of the judge, the City, as trustee o�
the Restricted Residence District, had a duty to initiate litiga-
tion over whether the Restricted Residence District was still
enforceable, rather than to wait for Plaintiffs to initiate such
litigation; and
WHEREAS, The Council finds that it is in the public interest
and for a public purpose to pay, as ordered by the Court, $25,OOQ
for Plaintiffs ' attorney's fees rather than to appeal this matter.
COUNCILMEN
Yeas Nays Requestgd by Department of:
Hunt
Levine In Favor
Maddox
McMahon B
Showalter __ Against Y
Tedesco
Wilson
Form Approved by City Attorney
Adopted by Council: Date —
CertifiE:d Passed by Council Secretary BY
By,
Approved by ;Navor: Date _ Approved by Mayor for Submission to Council 'I
By _ BY
� .,
WHITE - CITY CLERK �yy�,�y.����
PIyK � FINANCE �l l' J
Ca;�ARY - DEPARTMENT C I TY O F SA I NT ��U L COUIICII �� �
BL«E - MAYOR
File N .
Council Resolution
Presented By
Referred To Committee: Date
Out of Committee By Date
2.
to the Supreme Courtp now, therefore, be it
RESOLVED, That upon execution and delivery of a Satisfaction
of Judgment in full to the City of Saint Paul, the proper City
officers are hereby authorized and directed to pay out of the
Judgment and Compromise Fund 09065-512-000 to Russell Brown, Esq. ,
attorney for Karl Van D'Elden and others, the sum of $25, 000.
COU[VCILMEN Requestgd by Department of:
Yeas Nays
Hunt
�evine In Favor
Maddox �
McMahon B
Showalter __ A gai n s t Y —
Tedesco
�MI'rFSOR
AU6 2 5 1981 Form Approved by City Attorney
Adopted by Council: Date B �' �.Js
Certified Y .s by Counc.' ecr Y
Ap ro by Mayor. D e uG 2 6 ►98� Approved by Mayor for Submission to Council
B — BY
PllB11SHED S EP 519�
,.
-, ����s
t�t=��. CITY OF SAINT PAUL
R� ;
; � OFFICE OF THE CITY ATTORNEY
� iilt�ll��li o
. „ EDWARD P. STARR, CITY ATTORNEY
,... 647 City Hall,Saint Paul,Minnesota 55102
612-298-5121
GEORGE LATIMER
MAYOR
MEMORANDUM
TO: City Council Members
FROM: Edward P. Starr, City Attorney
Terrence J. Garvey, Asst. City Att ney
DATE: August 13, 1981
RE: Summit Avenue Restricted Residence District Lawsuit
During the last days of the legislative session, under Section
107 of the Transportation Appropriation Bill, an amendment to \
the statutes governing restricted residence districts was added.
That amendment reads as follows :
462.16. Power to enact ordinances for enforcement of
rights given to council
The council shall have the power to enact ordinances for
the enforcement of the rights which shall be acquired
under sections 462. 12 to 462. 17, and to fix penalties
for their violation, including a fine not exceeding
$100 or confinement in the city workhouse not exceeding
90 days. Violations of the ordinances may be prosecuted
in the municipal court of the city. Restricted residence
districts created pursuant to sections 462. 12 to 462. 16
shall be subiect to the provisions of section 541.023. In
construing the scope and effect of a residence district
restriction, equitable principles shall be utilized and
the following shall be considered: the historic pattern
of enforcement or non-enforcement; changed circumstances;
the lenath of time durinct which current uses have been
allowed to exist; the actual impact of current land uses;
and detrimental reliance.
.-"`�,O
.
,- ' �
Fr f t�Y�.A�
City Council Members
Page Two
August 13, 1981
That amendment appears to give additional support to the findings
of Judge Summers in the lawsuit concerning the use of 490 Summit
Avenue for a Catering Business. The judge, as you may recall,
further ruled that the Summit Avenue Restricted Residence District
was void and unenforceable between Dale Street and the Cathedral.
Nonetheless, the judge ordered the City of Saint Paul to pay
$25, 000 in attorneys ' fees to plaintiffs.
EPS:TJG:er
'� �����
._; ,
�'���==o, , ,.,. CITY OF SAINT PAUL
; , OFFICE OF THE CITY ATTORNEY
� ii11�11��i1 0
. � � EDWARD P. STARR, CITY ATTORNEY
,... 647 City Hall,Saint Paul,Minnesota 55102
612-298-5121
GEORGE LATIMER Au6 141981 �
MAYOR •
COUNEtCMAN
MEMORANDUM �QN MppDOX
TO: City Council Members
FROM: Edward P. Starr, City Attorney
Terrence J. Garvey, Asst. City Att ney
DATE: August 13, 1981
RE: Summit Avenue Restricted Residence District Lawsuit
' During the last days of the legislative session, under Section
107 of the Transportation Appropriation Bill, an amendment to
�
the statutes governing restricted residence districts was added.
That amendment reads as follows :
462.16. Power to enact ordinances for enforcement of
rights given to council
The council shall have the power to enact ordinances for
the enforcement of the rights which shall be acquired
under sections 462. 12 to 462. 17, and to fix penalties
for their violation, including a fine not exceeding
$100 or confinement in the city workhouse not exceeding
90 days. Violations of the ordinances may be prosecuted
in the municipal court of the city. Restricted residence
districts created pursuant to sections 462. 12 to 462. 16
shall be sub-iect to the provisions of section 541.023. In
construinq the scope and effect of a residence district
restriction, ec�uitable principles shall be utilized and
the following shall be considered: the historic pattern
of enforcement or non-enforcement; chanQed circumstances;
the lenctth of time durincr which current uses have been
allowed to exist; the actual impact of current land uses;
and detrimental reliance.
,
�..�",�,`7 �
�
`� ' �z`7���5
City Council Members
Page �vo
August 13, 1981
That amendment appears to give additional support to the findings
of Judge Summers in the lawsuit concerning the use of 490 Summit
Avenue for a Catering Business. The judge, as you may recall,
further ruled that the Summit Avenue Restricted Residence District
was void and unenforceable between Da1e Street and the Cathedral.
Nonetheless, the judge ordered the City of Saint Paul to pay
$25,000 in attorneys' fees to plaintiffs.
EPS:TJG:er
... ; �6��V
.��T��. CITY OF SAINT PAUL
�• ;
o . OFFICE OF THE CITY ATTORNEY
� i=i�ii�ii •
: ,.� EDWARD P. STARR, CITY ATTORNEY
�..• 647 Ciry Halt,Saint Paul,Minnesota 55102
GEpRGE LATIMER
612�299-5121
MAYOR
M E M O R A N D U M
TO: Council of the City of Saint Paul
FROM: Edward P. Starr, City Attorney, and
Terrance Garvey, Assistant City Attorney
RE: Judge Summers ' ruling on Summit Avenue
As you probably read in the newspaper, Judge Joseph Summers
recently ruled on a lawsuit concerning permitted uses on
Summit Avenue. In addition to what was reported in the news-
Aaper, Judge Summers orde�'ed the City of Saint Paul to pay
$25,000 to the plaintiffs ' counsel for attornegs ' fees. In
essence, the City prevailed before the court on the issues of
law but was ordered to pick up the tab for the losing parties '
attorneys ' fees . The novelness of Judge Summers ' ruling has
prompted us to apprise you in writing of the issues involved
prior to Council consideration of whether to appeal the court's
order. �
Summit Avenue has for approximately sixty years been subject to
certain use restrictions known as the Restricted Residence Dis-
trrct (RRD) . Land uses other than single family homes, duplexes ,
schools and churches were prohibited on Summit Avenue under the
RRD. Under the RRD prohibitions, for example, the canversion of
a 10 ,000 square foot mansion into three 3,000 square foot condo-
minium units would not be permitted. In the early 1950 's, then
private citizen Warren Burger challenged the issuance by the City
of Saint Paul of a permit to convert the property at 669 Summit
from a duplex to a fourplex. The validity of the RRD was upheld
by the Minnesota Supreme Court in Burger v. City of Saint Paul
(1954) . Notwithstanding the Supreme Court s ru ing, the RRD as
not been enforced. Most of the properties in violation of the
RRD restrictions are located east of Dale Street. About one half
of the structures between Dale and the Cathedral are in violation
of the RRD. Judge Summers ' order only applies to properties .
between Dale and the Cathedral .
� . O
.AF -
N /����
Memorandum
Council of the City of Saint Paul
Page Two
The suit before the court arose from two unrelated events . First,
the issuance by the City of a catering license in 1978 for
490 Summit Avenue and second, the opinior. issued by this office
in 1979 that the RRD was no longer enforceable. The initial
plaintiffs in the lawsuit were the nearby neighbors of 490 Summit
Avenue. Subsequently the Ramsey Hill Association, the Summit Hill -
Association and Old Town Restorations, Inc. , joined the lawsuit as
plaintiffs. The later plaintiffs objected to the determination by
the City Attorney's office that the Restricted Residence District
was no longer enforceable .
The property at 490 Summit is zoned RT-2. A catering business is
a permitted use in B-2 zone. The license application of the owners
of 490 Summit Avenue for a catering business was denied by the
License and Permit Division because the property was not properly
zoned for that enterprise. The applicant appealed to the License
Committee and the License Committee made the determination that it
was •permissible to issue a catering license for 490 Summit Avenue
for it was a continuation of a previously existing non-confarming
use.
Judge Summers made the following findings :
1. That the Summit Avenue Restricted Residence District
from Dale Street to Selby Avenue is void because con-
ditions have changed since its enactment as to nullify
its essential objecting purpose and to render continued
enforcement inequitable and contrary to puhlic policy.
2 . That to enforce the RRD against 490 Summit while not
enforcing it against the large number of other properties
along Summit Avenue which are in violation of the RRD
denies to the owners of 490 Summit Avenue the equal
protection of the laws .
3. That the Summit Avenue RRD cannot be enforced against
the present owners of 490 Summit because the RRD was
not filed of record with the Ramsey County Recorder and
these owners took title to the property without actual
notice of the restrictions .
4. That the use of 490 Summit as a reception house to
entertain social parties consisting solely of invitees ,
�.
�
�����
Memorandum
Council of the City of Saint Paul
Page Three
is a lawful use of 490 Summit under the Summit Avenue
RRD, such use being in accord with the purpose for
which the structure was built, even though a_fee is
paid for rental and food service.
5. That a reception house use of 490 Summit was a lawful
social building use in an A Residence District under
the 1922 Zoning Code.
6. That a reception house use of a structure is not a
permitted use in a RT-2 district under the 1975 Zoning
Code.
7. That the reception house use of 490 Summit was a lawful
non-conforming us� at the time the 1975 Zoning Code
became effective.
8. That the Council of the City of Saint Paul acted reason-
ably in determining that this lawful non-conforming use
at 490 Summit had not lapsed and in permitting the
Skally grQUp to continue a reception house use on the
property.
9 . Determining that defendant, City of Saint Paul, should
pay $25,000 for plaintiffs ' legal fees .
The dilemma which the court has left the City with is whether to
appeal on the issue of attorneys ' fees and risk the Supreme Court
overturning the trial court on the issues of law or whether to
pay the attorneys ' fees and accept the court's favorable ruling
on the issues of law. It is presumed that if the City appealed
from the court 's ruling on attorneys ' fees that the plaintiffs
would appeal to the Supreme Court on the court 's ruling on issues
of law.
Without publicly acknowledging the weaknesses of our case on
appeal, there are several findings of the trial court which would
cause some concern if an appeal is taken. Judge Summers ' ruling
is a substantial departure from the law as last set forth by the
Minnesota Supreme Court in Burger v. City of Saint Paul . The court
in Burger said that notwithstan ing economic rea ities or concerns ,
property cwners along Summit Avenue had a vested property right
in the Restricted Residence District for which they paid an assess-
• I
'.
�'`1�3�6
Memorandum
Council of the City of Saint Paul
Page Four
ment and even the state legislature could not take away that
�roperty right without compensating the individual property
owners for the loss . The last decision concerning the enforc�- ,
ability of the Restricted Residence District was made in 1973
by Judge Otis �odfrey wherein Judge Godfrey found the District
to still be enforceable. The case before Judge Godfrey involved
the use of a home at 958 Summit Avenue as a youth hostel.
The award by the court of attorneys ' fees to the nonprevailing
party is, as the court suggests, at first blush somewhat in-
congruous . There is , however, some support for the court 's
award of attorneys ' fees in the Burger case supra. In Burger,
the court noted that the City was t-fie trustee for the Restr cted
Residence District and that the City held all rights as trustee
for the benefit of the various property owners along Summit '
Avenue. The trial court found that the City in not enforcing
the RRD over many, many years and by not seeking a legal deter-
mination from the courts as to the enforceability of the RRD was
lax in its fiduciary duty as a trustee and therefore it was
justifiable to order the City to pay attorneys ' fees . It is our
understanding that the dollar figure awarded by the court is
approxim.ately one half of the bill submitted by the attorneys for
plaintiffs.
�
--- ���-. ���� ��
��
• ��=�o, ' CITY OF SAINT PAUL
~�� ' OFFICE OF THE CITY ATTORNEY
� nu��mu ;e
� "" ""' a5 EDWARD P. STARR, CITY ATTORNEY
• .... w� 647 City Hall, Saint Paul,Minnesota 55102
612-29&5127
GEORGE UTiMER
M/�YOR r� .. � � .. ,X° I
M E M O R A N D U M
TO: Council of the City of Saint Paul
FROM: Edward P. Starr, City Attorney, and
Terrance Garvey, Assistant City Attorney
RE: Judge Summers ' ruling on Summit Avenue
As you probably read in the newspaper, Judge Joseph Summers
recently ruled on a lawsuit concerning permitted uses on
Summit Avenue. In addition to what was reported in the news-
oaper, Judge Summers orde�'ed the City of Saint Paul to pay
$25,000 to the plaintiffs ' counsel for attorne�s ' fees. In
essence, the City prevailed before the court on the issues of
law but was ordered to pick up the tab for the losing parties '
attorneys ' fees. The novelness of Judge Summers ' ruling has
prompted us to apprise you in writing of the issues involved
prior to Council consideration of whether to appeal the court 's
order. �
Summit Avenue has for approximately sixty years been subject to
certain use restrictions known as the Restricted Residence Dis-
trict (RRD) . Land uses other than single family homes, duplexes ,
schools and churches were prohibited on Summit Avenue under the
RRD. Under the RRD prohibitions, for example, the conversion of
a 10 ,000 square foot mansion into three 3,000 square foot condo-
minium units would not be permitted. In the early 1950 's, then
private citizen Warren Burger challenged the issuance by the City_
of Saint Paul of a permit to convert the property at 669 Suznmit
from a duplex to a fourplex. The validity of the RRD was upheld
by the Minnesota Supreme Court in Burger v. City of Saint Paul
(1954) . Notwithstanding the Supreme Court 's ru ing, the RRD as
not been enforced. Most of the properties in violation of the
RRD restrictions are located east of Dale Street. About one half
of the structures between Dale and the Cathedral are in violation
of the RRD. Judge Summers ' order only applies to properties
between Dale and the Cathedral .
� � .�:�y�. �
. �:�.��,..�r:�=s ;
Memorandum
Council of the City of Saint Paul
Page Two
The suit before the court arose from two unrelated events . First,
the issuance by the City of a catering license in 1978 for
490 Summit Avenue and second, the opinion issued by this office
in 1979 that the RRD was no longer enforceab le. The initial
plaintiffs in the lawsuit were the nearby neighbors of 490 Summit
Avenue. Subsequently the Ramsey Hill Association, the Summit Hill -
Association and Old Town Restorations, Inc. , joined the lawsuit as
plaintiffs. The later plaintiffs objected to the determination by
the City Attorney's office that the Restricted Residence District
was no longer enforceable.
The property at 490 Summit is zoned RT-2. A catering business is
a permitted use in B-2 zone. The license application of the owners
of 490 Summit Avenue for a catering business was denied by the
License and Permit Division because the property was not properly
zoned for that enterprise. The applicant appealed to the License
Committee and the License Committee made the determination that it
was •permissible to issue a catering license for 490 Summit Avenue
for it was a continuation of a previously existing non-conforming
use.
Judge Summers made the following findings :
1. That the Summit Avenue Restricted Residence District
from Dale Street to Selby Avenue is void because con-
ditions have changed since its enactment as to nullify
its essential objecting purpose and to render continued
enforcement inequitable and contrary to public policy.
2 . That to enforce the RRD against 490 Summit while not
enforci;ng it against the large number of other properties
along Summit Avenue which are in violation of the RRD
denies to the owners of 490 Summit Avenue the equal
protection of the laws .
3. That the Summit Avenue RRD cannot be enforced against
the present owners of 490 Summit because the RRD was
not filed af record with the Ramsey County Recorder and
these owners took title to the property without actual
notice of the restrictions .
4 . That the use of 490 Summit as a reception house to
entertain social parties consisting solely of invitQes ,
Memorandum
Council of the City of Saint Paul
Page Three
is a lawful use of 490 Summit under the Summit Avenue
RRD, such use being in accord with the purpose for
which the structure was built, even though a .fee is
paid for rental and food service.
5. That a reception house use of 490 Summit was a lawful
social building use in an A Residence District under
the 1922 Zoning Code.
6 . That a reception house use of a structure is not a
permitted use in a RT-2 district under the 1975 Zoning
Code.
7. That the reception house use of 490 Summit was a lawful
non-conforming us� at the time the 1975 Zoning Code
became effective.
8. That the Council of the City of Saint Paul acted reason-
ably in determining that this lawful non-conforming use
at 490 Summit had not lapsed and in permitting the
Skally group to continue a reception house use on the
property.
9 . Determining that defendant, City of Saint Paul, should
pay $25,000 for plaintiffs ' legal fees.
The dilemma which the court has left the City with is whether to
appeal on the issue of attorneys ' fees and risk the Supreme Court
overturning the trial court on the issues of law or whether to
pay the attorneys ' fees and accept the court 's favorable ruling
on the issues of law. It is presumed that if the City appealed
from the court's ruling on attorneys ' fees that the plaintiffs
would appeal to the Supreme Court on the court's ruling on issues
of law.
Without publicly acknowledging the weaknesses of our case on
appeal, there are several findings of the trial court which would
cause some concern if an appeal is taken. Judge Summers ' ruling
is a substantial departure from the law as last set forth by the
Minnesota Supreme Court in Burger v. City of Saint Paul. The court
in Burger said that notwithstan ing economic rea ities or concerns ,
property cwners along Summit Avenue had a vested property right
in the Restricted Residence District for which they paid an assess-
i
Memorandum
Council of the City of Saint Paul
Page Four
ment and even the state legislature could not take away that
�roperty right without compensating the individual property
owners for the loss . The last decision concerning the enforce-
ability of the Restricted Residence District was made in 1973
by Judge Otis Godfrey wherein Judge Godfrey found the District
to still be enforceable. The case before Judge Godfrey involved
the use of a home at 958 Summit Avenue as a youth hostel.
The award by the court of attorneys ' fees to the nonprevailing
party is, as the court suggests, at first blush somewhat in-
congruous. There is , however, some support for the court 's
award of attorneys ' fees in the Burger case supra. In Burger,
the court noted that the City was tF�ie trustee for the Restr cted
Residence District and that the City held all rights as trustee
for the benefit of the various property owners along Summit
Avenue. The trial court found that the City in not enforcing
the RRD over many, many years and by not seeking a legal deter-
mination from the courts as to the enforceability of the RRD was
lax in its fiduciary duty as a trustee and therefore it was
justifiable to order the City to pay attorneys ' fees . It is our
understanding that the dollar figure awarded by the court is
approximately one half of the bill submitted by the attorneys for •
plaintiffs.
�