96-969�; � ; � -, � ; ; � M�E' N � �' t�
'� a� �.�e ? F� 1 r `
�� `� /RESOLUTIO�� t ��
Council File # �-�q
Green Sheet #
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Presented 6v ;
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Referred To \ � Committee Date
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1 BE IT RESOL D, that the Council of the City of Saint Paul hereby certifies and approves the August 6,
2 1996 decision of the Legislative Hearing Officer:
3 Pro�ert,L�pealed
4 843 Rice Street
5 Decision: Deny appeal.
6 740 N. Snelling Avenue
7 Decision: Deny appeal.
8 1075 Hudson Road
9 Decision: Deny appeal.
��'�evvsa '+o
�-�a� s�a�: v e..
11iqV ��O�C.QtCR✓
Aonellant
Linda Spencer
Kandi-Rain, Inc.
L & S, Inc.
10 1573 Selby Avenue, Apt. 246 Snelling Avenue Property Partnership
11 Decision: Grant variance conditioned on only the current tenant's occupancy of unit.
12 1913 Carroll Avenue Curtis Decker
13 Decision: Deny they appeal, with the exception of an extension for 90 days to complete repairs to the stairway
14 and replacement of windows and an eatension to August 6, 1997 for replacement of the roof.
15 266 E. Seventh Street Marion Rose/Pioneer Co.
16 Decision: Laid over to September 17, 1996 Properiy Code Enforcement meeting.
17 415 Sherburne Avenue (lower)� . Jeffrey Cody
18 Decision: Deny appeal. �-Q � d O V e Y' '�
Aw 199G
19 1748 Sheridan Avenue � L �` o vc r-1-0
20 Decision: Deny appeal. S� y' �Q9 �v
21
22
23
24
662 Canton Street
Decision: Grant appeal conditioned on re-occupancy within 90 days.
421 S. Wabasha Street
Decision: Grant appeal conditioned on re-occupancy within 60 days.
Kelly and Dana Mattingly
William Nichols
Allen Hartman
25 26 Dale Street, #107 Kingwood Management
26 Decision: Fire Prevention withdrew orders.
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1
2
1075 Sherburne Avenue
Decision: Crrant appeal conditioned on re-occupancy within 30 days.
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p. zo� 2 �l G-��9
Jean Noyes
FURTF�R RESOLVED, that tlus action shall become effective immediately upon approval of the Mayor.
Requested by Department oE
by Council Secretaty
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Approved by Mayor: Date
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Form Approved by City Attomey
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Approved by Mayor for Submission to Council
Adopted by Council: Date
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DEPAATMENTIOFFICFICDUNCII DATE MRIATED p
crrY courrcn. 8/6/96 GREEN SNEE N_ 3 6 4 3 4
MRIAVDATE IN(rIAUDATE
CONTACT PEfi50N 8 PHONE Q OEPARTMENT DIRE � CRY COUNQL
Gerry StratLman 266-8575 pSSIGN � CIT' ATfORNEV O CT' CLERK
MUST BE ON COUNCIL AGENOA BY (DAT� NUYBER FOR � BUDGET DIRECTOR � FIN. 8 MGi SERVICES DIR.
pOUTING
August l4, 1996 0�� � uaroa �oa nssisrnr.m 0
TOTAL # OF SIGNATUHE PAGES (CLIP ALL LOCATIONS FOR SIGNATURE)
ACfION RE�UESTED:
Approving the decision of the Legislative Hearing Officei on Properry Enforcement Appeals for ihe August 6, 1996 meeting.
RECOMMENDA71oNS: Approve (A� a Reject (R) pERSONAL SERVECE CONTRACTS MIiST ANSWER THE FOLLOWING �UESTIONS:
_ FLANNINCa CAMMISSION _ CIVIL SERVICE COMMISSION �� Has this persoMirtn ever worked under a conVact for this department?
_ CIBCOMMITTEE _ YES 'NO
_&TAFF 2. Has this personllirm ever been a city employee?
— YES NO
_ o15TAICT CAURT _ 3. Does this person/firm possess a skill not normally possessed by any curreM ciry employee?
SUPPORTS WHICH COUNCIL OBJEC7YVE? YES NO
Explain all yes answers on seperate sheet antl attach to green sheet
INITIATING PROBLEM, ISSUE, OPP�RTUNITV (Who, WPat, When, Where, Why):
ADVANTAGES IFAPPROVED:
DISAOVANTAGES IF APPROVED.
������ ������ �t��
i ;!� i� t� � �996
D�SA�VANTAGES IF NOTAPPROVED:
TOTAL AMOUN70FTRANSACTION $ COST/REVENUE BUDGETED (CIFCLE ON6) YES NO
FUNDIIdG SOURCE ACTIVITY NUMBEFi
FINANCIAL INFOflMATION: (EXPLAIN)
, $. MARK vA[JGHT � P � � � 1
Attoraev At Law
Suice 700
Six West Fifrh Saeet
Sainc Paul, Minnesora 55102
(612)297-6400
FAX (612) 224-8328
August 14, 1996
The Honorable David Thune, President,
The Honorable Jerry Blakey,
The Honorable, Dan Bostrom,
The Honorable Dino Guerin,
The Honorable Mike Harris,
The Honorable Roberta Megard, and
The Honorable Janice Rettman,
Members of the Saint Paul City Council
Third Floor
City Hall
15 west xellogg Boulevard
Saint Paul, Minnesota 55102
RE: Revocation of Certificate of Occupancy Proceedings
involving 740 North Snelling Avenue, 843 Rice Street,
and 1075 Hudson Road
Dear City Council Members:
I represent the following individuals or entities who are
aE£ected by the above referenced proceedings:
740 North Snelling Avenue
LeNOre A. Turner
Kandi Rain, Inc.
843 Rice Street
1075 Hudson Road
Linda May Spencer
L & S, Inc.
The Division of Fire Prevention, Department of Fire and Safety
Services has with respect to each of the three properties attempted
to revoke the respective certificates of occupancy under Saint Paul
Legislative Code (SPLC) §33.02 (d) which is reproduced in its
entirety and appended to this letter.
The matter appears befoze the City Council as a result o£ the
appeal of the attempted revocation by each of the named parties.
Each of the attempted revocations is flawed, both on
constitutional and 1ega1 grounds. While the following is not
intended as legal brief, it does discuss, first in general terms,
then in more speci£ic terms relating to each property, each o£ the
bases for the contesting of the revocations.
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DEFECTIVE NOTICE OF REt70CATION
Each of the notices issued in these cases is dePective. None
of the parties, by appearing before the Council, waives any right
to contest those defects in a judicial £orum, should the City elect
to proceed, despite notice of the de£ects.
The attempted revocation at 740 North Snelling Corporation was
by means o£ a notice over the signature o£ Phillip Owens,
Inspector, dated July 3, 1996, but which was, on in£ormation and
belief, actually delivered to the premises on July 2, 1996,
addressed to 740 North Snelling Corporation. No notice was served
or mailed, nor was service or mailing of a notice attempted, on
either LeNOre A. Turner or Kandi Rain, Inc. The tenancy of 740
North Snelling Corporation at 740 North Snelling Avenue was
terminated on November 1, 1995, and the premises was leased as of
that date to Kandi Rain, Inc., which is a Minnesota corporation.
LeNOre A. Turner was and is the £ee owner o£ the property at 740
North Snelling Avenue. The City had actual knowledge o£
termination of the tenancy of 740 North Snelling Corporation no
later than December 6, 1995, but virtue o£ service on that date
upon Virginia Palmer, Assistant City Attorney, of an Answer and
Counterclaim of LeNore A. Turner, pleading those facts with
specificity in a pending case in Ramsey County District Court,
entitled: Citv of Saint Paul vs. LeNOre A. Turner, et al.. Court
File No. C6-95-9723. Despite having actual knowledge of the
identity of both the fee owner and the tenant with current
possessory interest in the property at 74� North Snelling Avenue,
the City addressed no notice to either party and instead directed
the revocation notice to a party which had no interest whatsoever
in the premises, possessory.or ownership, legal or equitable, and
had not for a period of over seven months be£ore the notice.
The attempted revocation at 843 Rice Street was by means of a
notice over the signature o£ Phillip Owens, Inspector, dated June
27, 1996, but which was, on information and belief, actually
delivered to the premises on July 2, 1996, address to Thomas J.
Bieir, 78 lOth St. E., #2904, Saint Paul, Minnesota 55101. No
notice was served or mailed, nor was service or mailing of a notice
attempted on Linda May Spencer. Ms. SpenCer is the £ee owner o£ an
undivided one half interest in the property and has current
possessory rights to her interest in the property. The City had
actual knowledge o£ her interest in the property by virtue o£ an
Answer and Counterclaim of Linda May Spencer in a pending Ramsey
County District Court case entitled: Citv of Saint Paul vs. Linda
Mav Svencer, et al. Despite having actual knowledge o£ the
interest of Ms. Spencer in the property, the City made no ef£ort to
give her notice of this proceeding.
The attemp�Ced revocation at 1075 Hudson Road was by means of
a notice over the signature of Phillip Owens, Inspector, dated July
19, 1996, and, on information and belie£, delivered to 1075 Hudson
Road that date, addressed to R. B. Holden, et al., 1532 Dora Lane,
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Saint Paul, Minnesota 55106-6809. No notice was served or mailed,
nor was service or mailing o£ a notice attempted on L& S, Inc. L
& S, Inc. is the current lessee o£ the property and has a current
possessory interest in the premises. The City had actual knowledge
o£ the lease between Roger and Arlene Holden and L& S, Inc., dated
May 10, 1996, by virtue of the response o£ Roger and Arlene Holden
to a Request for Production of Documents served on them by the
City, which response was sexved on Virginia Palmer, Assistant City
Attorney, on 3uly 10, 1996 in a pending Ramsey County Bistrict
Court case entitled: Citv of Saint Paul vs. The �vorium, et al_
Court File No. C8-95-1476.
POSSIBLE STATE LAW PREEMPTION
SPLC §33.02(d) references and uses as a condition precedent
£or the invocation of the ordinance procedure the provisions of
Minnesota Statutes §617.81, subdivision (2), which is commonly
known as the public nuisance statute. That statutory provision is
appended hereto. In fact, the state statutory provision contains
its own method for en£orcement and does not contain an explicit
grant to the City of Saint Paul of authority to enforce the law in
any other manner than that laid out with the statute. As a matter
of record, the City was filed legal action under Minnesota Statutes
§617, subdivision (2) in Ramsey County District Court against all
three of the properties in question here and each of those three
lawsuits is currently pending. Arguably, the enforcement
proceeding under the statute preempts any attempt by the City to
use its own ordinances to enforce provisipns of state law.
SPLC §33.02(d) VIOLATES BOTH SUBSTANTIVE AND PROCEDURAL DUE
PROCESS GUARANTEES OF THE UNITED STATES AND MINNESOTA
CONiSTITUTIONS.
Each of the appellants in this matter is entitled, under the
Constitutions o£ the United States o£ America to both procedural
and substantive due process o£ law.
In the instant case, that translates to a requirement that the
City must furnish both procedural and substantive due process to
the appellants be£ore it can act to revoke the certi£icates o£
occupancy. The right to use of the affected properties pursuant to
a certificate occupancy is clearly a property right which triggers
due process reguirements.
One of the substantive due process constitutional guarantees
is that a given provisionss of law, such as SPLC §33.02(d), may not
be so vague that the reasonable person would find it impossible to
interpret and to ascertain what manner of behavior is proscribed by
the law. SPLC §33.02(d) utterly £ails the vagueness test and is on
its £ace unconstitutional. The very wording of the ordinance
allowing its application in those case were the £ire marshal
determines that certain behavior "m�" violate the state public
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nuisanCe statute on its face makes it impossible for a party to
determine what behavior is prohibited. The ordinance doesn't say
the behavior must or shall violate the state statute. Because it
does not, SPLC §33.02(d) is vague and unconstitutional on its £ace.
Further, a second substantive due process guarantee arises
invalidating laws which are overbroad in there application, that
prohibit conduct £ar in excess of that which is necessary to
accomplish the goal of the law. This defeCt clearly also exists
with this ordinance and also £lows £rom the use of the verb "m�".
The ordinance does not subject to sanction that behavior which does
violate the public nuisance statutes, but also that behavior which
mav violate. The behavior also mav not violate the public nuisance
statute and the City has no legitimate interest in prohibiting such
behavior. SPLC §33.02(d) is overbroad and unconstitutional on its
face.
THE CITY HAS PROVIDED AN INADEOUATE FACTUAL BASIS FOR
REVOCATION OF THE CERTIFICATES OF OCCUPANCY.
The notice generated over the signature of Phillip Owens in
each of these three cases contained only barest o£ conclusions that
the statutory condition precedent to the operation of SPLC
§33.02(d) had been met. That is, that the provisions o£ Minnesota
Statutes §617.81, subdivision (2) had been violated. The state
statutory provision require that a number of behevioral incidents
take place within a given period. It goes on to state that the
proof of each element of the nuisance must be "clear and
convincing", a standard in excess o£ the normal civil standard of
"by a preponderance of the evidence".
My clients submit that the preponderance standard isn't even
met in this case. What Mr. Owens has presented in conclusory form
for each address is the number of prostitution and disorderly house
arrests. He gives no details; no dates; no evidence as to who
might have been arrested; and no evidence of disposition of cases
which may already have worked their way through the court system.
In fact, at the hearing be£ore the Legislative Hearing OfPicer, Mr.
Owens admitted that he didn't know anything beyond the number of
arrests and had relied on the police £or that information. And
since that hearing and despite that fact the lack o£ factual basis
was raised by my clients, the City has not supplemented the £acts
at all. There really is nothing for my clients to rebut. They can
only guess. The fact situation in this case is actually identical
to the situation as if an o£ficer of the State of Minnesota
appeared at your door, or that of your next door neighbor, with a
notice of revocation of your drivers license because you had three
maving violation tickets in a year, but then refused to tell you
when the violation triggering the tickets occurred, who was driving
the vehicle, and how fast the vehicle was going, what the o££ending
behavior was, and whether or not the three tickets all flowed from
the same behavioral incident.
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The minimal facts presented in this case don't prove the
violations by a preponderance of the evidence, let alone by the
required clear and convincing evidence.
My clients can make this limited challenge to the facts. The
state statutory provision dePines the type o£ behavioral incidents
in terms o£ "prostitution and prostitution related activity". The
statute defines "prostitution and prostitution related activity" in
such a way that arrests £or visiting a disorderly house, which are
the bulk o£ the claimed arrests, are excluded and are not a basis
for adjudging violation o£ the statute.
Further, my clients suspect, but do not and cannot know, on
the basis of the wholly inadequate facts available to them, that
many of the charges have been dropped by the prosecuting
authorities or dismissed by the courts. I£ they have been, they
clearly don't qualify. And, my clients, suspect, but do not know,
that some or all of claimed arrests were created by the Saint Paul
Police Department during its illegal seizures o£ one or more o£ the
properties.
THE APPELLANTS WILL PURSUE THEIR LEGAL REMEDIES IF THE CITY
PERSISTS IN THESE MATTERS WITHOUT REMEDYING THE DEFECTS.
As many o£ you know, this is not the first time the City has
attempted en£orcement actions against these premises. And most of
you also know that on previous occasion the City has been rebu££ed
in those attempts beCause it failed to follow the law. Whatever
the alleged political popularity of these actions, they fall
utterly and completely short of the legal and constitutional
requirements and when combined with past illegal failed attempts by
the City have crossed the line o£ civil actionability. There£ore,
my clients intend i£ the City persists in this latest round of
illegal actions to pursue their full legal remedies including an
action £or damsges against the 42 United States Code §1983 for
attempting, under color o£ law, to deprive my clients o£ their
property without due process of law and without just compensation.
.� Ver truly r {��� ) o � . urs, ,/
�C/L- / L�LC� J
S. Mark Vaught
Attorney at Law
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Certi£icate of Occuvancv Anueal Hearinqs
Saint Paul Legislative Code §33.02(d)
"Revocatioa. The fire marshal may, in writing, suspend or
revoke a certificate of occupaacy issued under the provisions
of this code whenever the certificate was issued in error, or
on the basis of incorrect i.nformation supplied, or when it is
determined by the fire marshal that a use of the building or
structure or portion thereof may constitute a auisance as
described in Minnesota Statutes, Section 617.81, subdivision
(2), or is in violatioa of any ordinance or regulation or any
provision of the Saint Paul Legislative or Administrative
Code."
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Minnesota Statutes §617.81, Subd. 2
Subd. 2. Acts constitutiag a nuisance. (a) For pt�*r+oses of
section 617.80 to 617.87, a publi nuisaace exists upon proof of two
or more separate behavioral incidents of one or more of the
following, co�itted within the previous 12 months within the
building, or i£ the building contains more than one rental unit:
(1) within a singie rental unit; or (2) within two or more rental
units leased or controlled by the same person:
(1) prostitution or prostitution-related activity cammitted
within the building;
(2) gambiing or gambling-related activity co�titted within the
building;
(3) keeping or permitting a disorderly house within the
building;
(4) unlawful sale, possession, storage, delivery, giving,
manufacture, cultivation, or use of controlled substances committed
within the building;
(5) unlicensed sales of alcoholic beverages commiteed within
the building in violatioa of section 340A.401;
(6) unlawful sales or gifts of alcoholic beverages by an
unlicensed persan co�itted within the building in violation of
section 340A.503, subdivision 2, clause {1); or
(7) unlawful use or possession of a firearm in violation of
section 609.66, subdivisionla, 609.67, or 624.713, committed within
the building.
(b) Proof of a nuisance exists if each of the elements of the
conduct constituting the nuisance is established by clear and
convincing evidenae.
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Minnesota Statutes § 617.80
Subd. 4. Prostitution. "Prostitution" or "Prostitution-
related activity" means conduct that would violate section 609.321
to, 609.324.
Subd. 6. Disorderly house. "Disorderly house" has the
meaning assigned to it in section 609.33.