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1031 Cliff Rd - Special Assessment Appealr ' r ? • BOTICE OF A33FS.SlM HAHING CITY OF EAGAN DASO'!1 COOHTY9 !IIl19SSOSA NOTICE IS HEREHy GI9ENO that the City Council of the City of Eagan, Dakota County, Flinnesota, xill meet at the Eagan lfimicipal Ceater located at 3830 Pilot Rnob Road, in said City on October 6. 1988, at 7:00 p.m. to consider the proposed assessment of Parcel # 10-02600-011-52 For Project # 444R in Eagan. The proposed area to be assessed is described in the assesameat roll on file with t4e City Clerk in his officep xhich roll is open to public inspection. Writtea or oral ob3ections will be conaidered at the public hearing. An owner may appeal an assessment to distriet court purauant to H.S.A. 429.081 by serving notice of the appeal upon the Mayor or Clerk of the City of Eagan within thirty (30) days after the adoption of the assesament and Piling such notice vith the Distriet Court of Dalcota County vithin ten (10) days after service upoa the Mayor or Clerk. Further informatioa relatiag to these assessments may be obtained Prom the Special Assessment Division oP the Fiaanee Department and any questioas ahould be directed to that Diviaioa. Dated: September 220 198$ E J aa0verbeke Citq lerk, Eagan e - • Iv - o aboo -o//-s- z- UCF.100(4491 - w«o. a Fw4h erw. oou,.ww rJoseph P. Earley Attorney at Law 7300 W. 147th St., Sox 24329 Apple-Valley, MN 55124 L - rThomas W. Bihus Attorney at Law Box 2038, Suite 103 6575 Cahill Ave. E. LInver Grove Aeights, MN 55075 STATE OF MINNESOTA COUNTY OF Dakota NOTICE OF: 10 FILING OF ORDER m ENTRY OF JUDGMEM ? DOCKETtNG OFJUDGMENT Court File No.: C2-88-8935 IN RE: City of Eagan etc. vs Martin DesLauriers etal eec. 13 Ybu ere hereby nodfted thet on Mav 24th , 18 $9 an Order was duly flled in ihe ebove entitled matter. ? You ere hereby notifled that on Mav 24th , 1g 89 g Judgment was duly antered 1n the above entltied marier. 13 You ere hereby notiHed that on , 19 a Judgment was duly dxketed In the above entiUed matter In the amount of _ A true and correct copyof thla Notlce has been aerved by mall upon lhe parllea named herein at the last known address of each, pursuant to Minnesota Rules of Ctvfl Procedure, Rule 77.04. Dated• Mav 24th 1489 RoQer W. Sames • Court Administrator by S?lLeLL? JLaZtj? eA-,/ Deputy COURT ADMINISTRATOR DAKOTA COUNTY, MfNN. s.. F I l E D « MAY 24 1989 RO(iER W. 5AME3, CLERK '""0A? x? °' ?+?BEPUTY 5"1:17'E OP h1]NNESOTA couNr'y vr u,uioTA COURT ADMINISTRATOR DAKOTA COUNTY, MINN. F I!E D MAY 24 1989 N93ER W. SAMES, CLEhK ,! DErurr City of Lagan, a miinicipal corporat'ton. I'etitioner/ftespondent, cs. Plartin DesLauriers and hfarie I)e:;I,auriers, husbflnd and caife, Appellants. IN DISTRICT COURT FIRS'P JUDiCLAL DiST}tl(.1' Court Pile No. C2-88-8935 FINDINGS OF FACT CONCLUSIONS ON' LAW ORllER FOR JUDCMENT AND JUDGMENT 'Che above-entitled matter came on for trial befure the undox•signed Judge of liistrict Court on the 4th duy oP May, 1989, .it the C.overntnent Cent.er, Hastings, Minnesota, regarding an apPeal of the assessment of the DesLaur.iers Yarcel 10-02600-0011- 52.. Jo3Pph 11. Earlep, l:sq., appearec] representing the Pet,itiouer•/he:;pondent. Thomas W. Bibus, Esq., appeared ?epresentin, the Appe.tlants. Nocc, theref'ore, based upon the file, records and proceedinqs hcrcin, the i;otirt being diily advised in the premises makes the foi.lowing FINDINGS OP PACT: ILI 7'hat, the City of Engan shall be hereinafter referred to a^, Cit}- 1nd the Appellants hereinafter referred to as DesLauri.crs. (2) '1'bat the Itespondent herein is s municipal corporation 1 c,nd. as si.ich, has completed a storm sewer project for the }'urposes herein thut runs in front of the Appellants' home located on Cliff Ctoad in Psagan, Minnesot.a. Said project is known as the liollniid Lxlce Trunk Storm Sewer Yroject 4•14R. (3) Phat the DesLauriers own a 6.3 acre tract on Cliff Itoad; that a portion uf that property had previously been subject to a r.ondemnation, and the CiCy has erected a lift station on 13<fid 1]['pj](J•tV. SII1CI li.ft station is used in connection wzth this storm sewer pro,ject. 1=11 That the DesLauriers bought this propertv in 1977 and, shortly ttiex•eai'ter, erected a home in the northeast portion of Lhc propert.y; that distances were not made available to the Cour•t, but it is some distance from the house to Cliff Road and servicr-.d I,t- fl gravel drivewaY; that the portion that is nearest Cliff Rond i¢ lower arid, E'rom time to time, wottld acCUmulate weiter. T1ie nltural runoff of the surrounding terrain ran the +;at cr into that ].ow nrea. 'Phe wuter then passed through a riilvert nnder the DesLauriers' driveway into the propertc i.mmediat(-lz• east, referred to as Carlson Pond. When Carlson Pond x•eached ti cer-tain lecel, the water exited Y.hrough a culvert under rliff Koad iiito Lalce Ilc>lland. 1'his flowage of water apparently has exi:7tecl for some period of t,ime. (5) 'Chat FAL LI]e apperent urgi.ng of the County of Uakota to close oi'F Lhe storm water runoff into Lake Holland, the Citp rrected t.his sl;orm seraer system. (G) 'fhat the City has determined that the DesLauriers' 2 f"ropert.y has improved L.v $9,500.00 due to the construction of the storm scwer, and have so nssessed the propertv in thaL Amount. 171 That Che UesLauriers hace objected; hence, this LiLigntion. (8) That the memorandum attached hereto shall be incorporated herein and made part of the Findings. Ivoca, theref'ore, based upon the foregoing, the Court makes tlie following CONCLUSION OF LAW: 'Chat the llesLauriers' property, Parcel 10-02600-0011-52, has not, beneFited by the storm sewer installation; that, as such, this property sJlould net be assessed for this pro,iect. LGT JUDGMGN'I' EtE ENTERED Ai;COliDiNGLY, BY THL C'()Uft'I': UateJ: May 23, 1989 MEP10Rr1NllUP1 The citp in thi.s matter finds itselt' with the usuall,r- difi'icult problr-m of endeavoring Lo prove that the DesLauriers' i-irayerty ha:; improved tlirough the install.ation of an overall city improvemenl. A subst.ariti-al lmount of acreage is serviced b,y the storm ,^,ec.-cr und ]ifL stution t.haC was put on the DesLauriers' propcrty :;s it 1i['1..=; the water uut, of Carlson Pond. Said w,tter preriously ran under C'l.iCf Road and into Lake Fiolland. The i.'oifrt, heiug aware of Lalte Halland, Tinds that it would tal.e a 3 storm of biblical proportions to overflow the banks of Lake 11011aiid and Plnod ClifF Itoad. The City does have t}ie burden of showing that Che assessment of $9,950.00 improves the DesLauriers' property bp an amount eqtial or grenter than that. The Court does not find that the City has mct its burden. "Che City in its presentation to the Court stated that the his;hest and best use of the property would be single family dwvlling. It now serves that purpose. The home owner had no problem dealing with his runoff water Uefore this sewer was inst;alled by Lhe City. It was not for his benefit that the sewer s}stem wns inst.alled, but for the henefit of the community at lcnr-;e. 7'Ite Coiu•t, reca.lls the fit;ure of approximately 2,700 acres i m m o diatel>• cast of the ?esLauriers' property being served by this set.ei• sgslem. Apparently, there is ].itt].e or no ittcrease in thc- amount si.rvir_ed through the DesLauriers' property bp this s}'s , i.em. Fvoti tliough ttiis new sz'stem does not ylace any- $reater burden ou t,he besLauriers' propert,v, it is not more beneficinl to Lis runo ff sitiiation. Zf the hiqhest and best use of the properL3', as set 1'orth by the City, is as it is now, single 1'amily dwe7.]ing, then it makes little sense for the City to talce the? position that it, is a substantisal improvement to the De;;L.%iurier property if theg eaer wanted to develop the same, 'I'Le Court hus difYic:ulty in accepting the evaluations placed uu the property by Clie Cit,Y. The CourC noted that, bef'ore the ral lec;ed irnprovement, Chc° property was served by cL bituminous 4 roadwav and electri.r_ity; that, in tlie after situation, the prupertc was served by bitum.inous roadwa}•, electricity and trunk amx sLorm sewer. ln ever}• compArable, the comparative property s.as serve(l L,c all ut.i7.ities, whi.ch are described as i.ncluding :zas, clectricity, Snnitary sewer, water, storm sewer and bittnni.nous roadwacs. There has been no objection to the process or the procedure involved hereiu. The matter simply comes down to a judgement cal.l by the Court bzsed upon the evidence that was presented, the cvaluai,ion oF the documentation, nnd the evulufltion of the witnesses calJ.ed before the Court in malting its determination. A. sucii then, the Courl, finds4t,hat t,he City has not sustained its hurden 1.^, i:o showing, by a fair preponderance of the evidence, thnt there hus been any improvement to the DesLaurier property. The Court also notes t.he 1'act that it received, unsolicited, n lettei frnrn John J. Iilein, the home owners' appraiser. Upon opcuing 1hN entie]ope, the Court, noted that .it contained a letter direct.ed t.n t.he Courl:, plus some appflrent, eshibits. When the Court. resi] ircd thtit it r.elated to this case, the material was placed bnck in the envel.ope and not read or reviewed 6y the iiudersi.v,ned. Mr. lU_cin may he well menning, but the Court takes ?i•ievous offense at a witness who, apparently on his own \oliti.on, attempts Lo intervenn and, et parte, influence the C'ourC. 'Che parties c:in be assured that Ptr. Klein's e>:traneous efl'orts d,d not: inftuence the Court in making its determination uuc wn}- ur the other. '1'.P1.M. 5 2 '. . ? I hereby certify that the Conclusion Of Law contained in this document shall constitute the Judgment of this Court. Date: May 24th 1989 ROGER W. SAMES Court Administrator Seal By Deputy Clerk STATE OF MINNESOTA COUNTX OF DAKOTA Martin DesLauriers and Marie DesLauriers, husbanci ano wife, Appellants, v. City of Eagan, a municipal corporation, Responaent, DISTRICT COURT FIRST JUDICIAL DISTRICT Court File No.: C2-88-8935 Case Type: Special Assessment Appeal RESPONDENT'S CLOSING ARGOMENT BRIEF Respondent, City of Eagan, respectfully submits the following brief in lieu of a final argument in the above-captioned matter. INTRODUCTION Respondent submitted a trial brief at the commencement of the trial which set out the facts, a synopsis of the anticipated testimony, the issues and law as it pertains to this case. In this brief, the Respondent will not restate what has already been stated but will high-light the testimony of witnesses at trial as it pertains to the issue and 1aw in this case. APPELLANTS' WITNESSES In the Appellants' case in chief, they called two witnesses. The two witnesses were Martin DesLauriers, lanaowner ana John Klein, appraiser. Page 2/RESPONDENT'S CLOSING ARGUMENT SRIEF - City of Eagan/DesLauriers RESPONDENT'S WITNESSES Respondent called three witnesses. Thomas Colbert, Director of Public Works for the City of Sagan, Robert Rosene, City of Eagan Consulting Engineer, and Daniel Dwyer, appraiser. ARGDMENT Appellants and Respondent stipulated at the beginning of the trial that the sole issue to be decided by the Court was whether or not the assessment of Appellants' property exceeded the special benefit to that property resulting from the storm sewer improvement. To determine the value of a special benefit, the taxing authority must consider what increase, if any, there has been in the fair market value of the benefited land. Carlson-L•ancae Realty Co. v. C.tv of Win6om, 307 Minn. 368, 369; 240 N.W.2u 517, 519 (1976) The standard of review in this matter is f or the Court to make a clecision based upon inclependent ana cIe novo consideration of all the evidence. "... [W]here the sole issue presented is whether there has been an unconstitutional taking, the trial court cannot abrogate its duty to uphold constitutional safeguariis and defer to the judgment of the taxing authority. Decision must be based upon independent consideration of all the evidence." Buettner v. Gity of St. Cloud, 277 N.W.2d 199, 203 (1979) Page 3/RESPONDENT'S CLOSING ARGUMENT BRIEF - City of Eagan/DesLauriers I. Appellants' pronerty benefited by the storm sewer improvement. Respondent, through the testimony of Mr. Colbert ana Mr. Rosene, demonstrated a qualitative specific benefit to Appellants' property. "Usually if property receives better municipal services ana amenities, it is woxth more." Schumacher v. City of Excelsior, 427 N.W.2d 235, 238 (Minn. 1988) Mr. Colbert, the City's Public Works Director, has years of experience as a civil engineer. He is also very familiar with Project 444R. Mr, Colbert testified that Appellants' property is better off with the current storm sewer availability than it was with gravity drainage into Hollan3 Lake. Both Mr. DesLauriers and Mr. Klein admitted on the stand that the highest and best use of the Appellants' parcel is development as single family lots. Mr. DesLauriets stated that the property is well suited for executive style family homes. He f urther adrnitteci that he purchased the property for a homesite anci "investment" reasons. Mr. Colbert concurtea with Appellants' conclusion that the parcel's hiqhest and best use was resiaential ueveloXxnent. However, Mr. Col6ert also testified that the development of the parcel woula increase the drainage in the system. Mr. Colbert, after explaining how the old drainage system was nearing capacity, explained the DesLauriers parcel was undevelopable without the storm sewer improvement of 444R. The drainage system was reaching capacity before the storm sewer project was installed. Mr. Colbert explained how the Page 4/RESPONDENT'S CLOSING ARGUMENT BRIEF - City of Eagan/DesLauriers lift station on the Carlson Pond (east of DesLauriers property) gives the City control over the level of the pond, The City has also acquired a ponding easement over the Carlson Pond. This prevents Carlson from altering the pond's capacity. Mr. Colbert testified that the acquisition of this easement eliminated the need for an easement on the DesLauriers property and also gave the City control over the level of the pond using its newly installetl lift station. Mr. Klein, in his testimony for Appellants, said there was no benefit to the ptoperty as a result of the storm sewer improvement. He based his conclusions in large part on his perception that the drainage across the DesLauriers parcel was increased from 70 acres to over 2,000 acres. These statements concerning the increased drainage across Appellants' parcel are false. Mr. Colbert testified that prior to the storm sewer improvement, the arainage flowing into ana across the Appellants' property was less than 70 acres and that after the storm sewer improvement, the drainage flowing into and across Appellants' parcel remained less than 70 acres. Mr. Colbert testifieo that there was no alteration to the existing culvert connection between Appellants' property and the Carlson Pond. While the arainage into the Carlson Pona has been increased, the Carlson Pona is four feet lovrer than the DesLauriers pond. The capacity of the lift station to remove water from the Carlson Pond exceeds the flow into the Carlson Pond ana this capacity has never been exceeded. Mr. Colbert testified that there has never been any water backing up into the DesLauriers' pona. Page 5/RESPONDENT'S CLOSING ARGUMENT BRIEF - City ot Eagan/DesLauriers Mr. Rosene, the City's consulting engineer, also confirmed that the Appellants' property was benefiteu by the storm sewer improvement. He explained how Holland Lake was backing up aue to the excessive drainage into it; that it had already risen five feet and could have risen another five feet if corrections hadn't been made. This rising of Holland Lake which is directly across the street from the DesLauriers parcel yave rise to the possibility oE flooding of Cliff Roaa and the DesLauriexs property. Without this storm sewer improvement, the Appellants' would have had to substantially increase the on-site ponding capacity if the property were to ever develop. Mr. Rosene is well-qualifiEd to speak to benefit to the property. He has been a consulting engineez for the City of Eagan for over 30 years and has been personally involvea in the original storm sewer plan and every revision of that plan to the present. Mx. Klein is well aware of the benefit accruing to property as the result of a storm sewer improvement. He acsmitted the necessity of the storm sewer system in Eagan. He testified that he was instrumental in its design. Mr. Klein admitteci that during his tenure on the Eagan Town Board, he approved the assessment of many residential properties for the installation of storm sewer systems. Mr. DesLauriers admits that his property always had water on it for aday or two after a rain. He also admitted that he had altered the terrain of his property by clearing and dreaging to create a permanent pond after the installation of the storm sewer system. The current ponding on Appellants' parcel is a result of the grading and not the storm sewer system, P1r. DesLauriers has been awaraea tlamages Page 6/RESPONDENT'S CLOSING ARGUMENT BRIEF - City of Eagan/DesLauriers for the taking oE the lift station in a previous condemnation action. Mr. DesLauriers also questioned the Lact that he was not credited for a ponding easement in his assessment. However, he admitted that he has never given an easement to the City of Eagan for ponUing on his property. The City is not obligated to credit a non-existing easement. If an easement is needed in the future, the City will have to acquire it by negotiation or eminent domain. II. gppe7lants' property has bePn benefiterl by the storm sewer improvement in an amount aual to or greater than the $9.500.00 the p.zooerty was asses n fnn c co t P oject 444R. "To determine the value of a special bene£it, the taxing authority must consider what increase, if any, there has been in the fair market of the benefiteci land.... The increase in market value is calculateci by determining what a willing buyer uncier ordinary circumstances woulU pay a willing seller for the property betore an? then after the improvement has been maae." Carlson-Lange Realty Co., 307 P7inn, at 369-70, 240 N.W.2d at 519. Mr. Daniel Dwyer, the City's consulting appraiser, establishea that the special benefit realized by the Appellants increased the market value of their property by $9,500.00. Mr. Dwyer is an expert appraiser with over 17 years of experience. He personally inspected the property on several occasions. His appraisal was based on the market value before and after the storm sewer improvement. He testified that a developer would be willing to pay more for the Page 7/RESPONDENT'S CLOSING ARGUMENT HRIEF - City of Eagan/DesLauriers property with one of the three utilities (storm sewer, sanitary sewer and water) already present. Mr. Dwyer based his appraisal on residential use of the property. Mr. Dwyer based his appraisal on the value of the land only. He submitted a written report ana reviewed it for the Court. This report included ten comparables, both in the before anci after situation which were used anc3 adjusted by Mr. Dwyer to determine the current market value and benefit to Appellants' property. Mr. Dwyer's conclusions as to value were based on the potential ability to develop the site more intensely; the elimination of hazaros created by on-site ponding; the elimination of recurring street maintenance and floocaing problems in the immediate and general areas and controlling the water level of the various ponding areas in the immediate area. Mr. Dwyer made an impartial ctetermination of market value for Appellants' property. His value was less than that proposed to be assessed by the City. The City, through their Special Assessment Committee recommendeci that the market value be adopted as opposeo to the original proposed assessment. This shows the City's good faith effort to determine and assess for market value increase only. Compaze Mr. Dwyer's determination of value with that determination mane by Mr. Klein. Mr. Klein's claim of no increase in value is not substantiated by any credible evidence. Mr. Klein presented no appraisal report evaluating the before and aftet market value due to the storm sewer improvement. He presented no comparables by which to judge market value increase. Mr. Klein's credibility as Page 8/RESPONDENT'S CLOSING ARGUMENT BRIEF - City ot Eagan/DesLauriers an appraiser is questionable based on the appraisal he aid do for the DesLauriers parcel for the condemnation action, in that appraisal, he admitted finding a before taking value of the property of over $498,000.00. This, when Mr. DesLauriers had attempted to sell the entire parcel unsuccessf ully for three years for no more than $230,000.00. CONCLUSION Appellants' property has been benefited by the storm sewer improvement in an amount equal to or qreater than the $9,500.00 the property was assessed for the cost of Project No. 444R. The Court should enter its ortler dismissing Appellants' appeal of the special assessment, Dated: McMENOMY & SEVERSON, P.A. By: Joseph P. Earley Attorneys for Responcaent, City of Gagan 7300 West 147th Stxeet P.O. Box 24329 Apple Valley, MN 55124 (612) 432-3136 I.D. No. 189595 STATE OF MINNESOTA COUNTY OF DAKOTA Martin DesLaur.iers and Marie DesLauriers, husband and wife, Appellants, v. City of Eagan, a municipal corporation, Respondent. DISTRICT COURT FIRST JUDICIAL DISTRICT Court File No: C2-88-8935 Case Type: Special Assessment Appeal APPELLANTS' TRIAL BRIEF Appellants, Martin DesLauriers and Marie DesLauriers, husband and wife, zespectfully submit the following Trial Brief in the above-captioned matter. INTRODUCTION This case is a special assessment appeal atising out of a decision by the City of Eagan to adopt a final assessment of $9,509.00 against property owned by Maztin and Marie DesLauriers located at 1031 Cliff Road, Eagan, Dakota County, Minnesota (Tax Parcel No. 19-92600-0011-52). The City's position is that the landowner.s received both qualitative.and quantitative benefit at least in the amount of $9,500.00 as a result of the Storm Sewer Pcoject No. 444R. The Landowner/Appellants' position is that the land did not benefit in any manner from the storm sewet project and in fact was damaged as a result of it. ARGUMENT "The cost of any improvement or any part thereof, may be assessed upon property benefited by the improvement, based upon the benefits received." Minn. Stat. Section 429.051 (1988). The value of a special benefit is determined by considering the subject property's increase in fair market value. Carlson-Lang Realty Company vs. City of Windom, 307 Minn. 368, 369, 240 N.W.2d 517, 519 (1976). The increase in market value is determined by "what a willing bnyer would pay a willing seller for the property before, and then after, the improvement has been constructed." Id. at 369-70, 240 N.W.2d at 519. There is a presumption of assessment validity which may be overcome by competent evidence. Id. at 370, 240 N.W.2d at 519. "(AJ special assessment which exceeds the special benefits to the property is a taking of property without Eair compensation in violation of the Eourteenth Amendment," Buettner vs. City of St. Cloud, 277 N.W.2d 199, 202 (Minn. 1979). I. APPELLANTS' PROPERTY llAMAGED BY STORM SEWER PROJECT N0. 444R. The Appellant/Landowners' property has not benefited by the Storm Sewer project No. 444R and in fact has been significantly damaged by the pxoject. As the testimony and exhibits indicate, a new HWL (high watee level) of 880 has been imposed on Appellants' land as a result of the storm sewer project. This now effectively eliminates any development on Appellants' property below that HWL. In fact, the exhibits and the facts available to both sides clearly indicate that there will be a significantly large ponding area of 1 to 2 acres now required on the landowners' property as a result of the storm sewer project. Although witnesses for the City testified that they did not feel a ponding area would be required, the facts speak differently: 2 1. By the very nature and design of the lift station on Appellants' property, any amounts of water in the adjoining landowners' (Carlson) pond that exceeds the pumping capacity of the lift station will flow through a culvert onto the DesLauriers property. The system reguires ponding area on the DesLauriers property for time periods when the pnmping capacity is overcome or the lift station is not operable. As mentioned in the testimony of Public Works Director and City Engineet Thomas A. Colbert, the lift station does not have an independent source of electrical power and has no emergency generator. Thus, in any storm situation where the lightning causes a power failure, DesLauriers' property will flood. 2. The City of Eagan Appraiser, Daniel E. Dwyer, indicated in his testimony on cross-examination about his earliet Condemnation Appraisal Report dated July 1, 1987, that he did in fact indicate in that report that some portions of the DesLauriers property could be flooded or suffer increased water flowage as a result of the project. He also admitted stating in his earlier Condemnation Appraisal Report that the City of Eagan has requiiements foc developers to allow for starage or ponding capacity to handle any proposed development of a parcel. If the DesLauriets property was developed to a more intense use than a single-family dwelling, he admitted indicating in 3 his report that the owner/developer would have to allow for water storage or ponding on the property. 3. The original Assessment Roll for the DesLauriers property indicated an estimate of futuxe right-of-way for ponding purposes of 20,094 square feet. 4. The City of Eagan Consulting Engineer, Robert W. Rosene, indicated in one of the exhibit lettecs dated October 21, 1986, that "it is anticipated that 4.2 acre feet of storage will be the total volume required on your property." 5. The exhibit diagrams originally prepar.ed by the City all indicate ponding area on the DesLauriers property as part of the Storm Sewer Project No. 444R. Quite apart from the argument that there has been a"taking" of Appellants' land as a result of the storm sewer project, (an argument that more appropriately belongs in a condemnation proceeding), is the valid and mote pertinent argument that the DesLauriers property has been damaged and not benefited by the storm sewer "improvement". The City of Eagan's argument is that the DesLautiers property, which has as its highest and best use a single-family dwelling, is qualitatively and quantitatively benefited by the storm sewer project. Yet the single-family residence is located in the back corner of the property on considerably higher ground than where the lift station is located. 4 If, as the City argues, the highest and best use of the property is for a single-family residence located on very high ground, then how could the DesLauriers' conceivably benefit from this storm sewer project? The City attempts to argue thinqs both ways and states that there is now more "potential ability" to develop the DesLauriers property more intensely, but in fact the City's storm sewer project has resulted in a higher HWL which will prevent any development below that figure of 880. The storm sewer project has hindered not improved the potential ability to develop the site. The City also argues that thexe has been a benefit to the property in that there has been an elimination of hazards created by on-site ponding. On the DesLauriers property, there used to be no ponding requirement and now there is. There used to be no stopage of the normal flow of water off of the DesLauriers property and into Holland Lake and ?ow there is. There used to be no requirement of trusting a machine (lift station) subject to frequent malfunctions and now there is. The so-called "new control" of the water levels in the immediate area is at a level higher than ever before. For the pzivilege of the DesLauziers' sufferinq such serious damage to their property, they are now being assessed in the amount oE $9,500.90. An example of how a piece of property can be damaged and not benefited as a result of a storm sewer project, as measuted by the market value of the property beEore and after the storm sewer project/ is contained in the Comparable Sales of the City of Eagan's Appraiser, Daniel E. Dwyer. The Appellant/Landowners' Appraiser, John J. Klein, pointed out in his testimony that Before Comparable 5 Sale No. 3 and After Comparable Sale No. 1 are adjoining pieces of property. Before Sale No. 3 occurred in June of 1985 and this property was served by electricity and sanitary sewer only. This was a"cash" sale which generally shnuld be for less money than a "time" sale. Yet this property sold for $17,360.00 per acre in compaxison to the Aftez Sale No. 1 which sold for a total price of $16,000.00 per acre. After Sale No, 1, which occured July 23, 1987, was a parcel that was served by all utilities and involved a large contract for deed. After Sale No. 1 was in the immediate area of the DesLauriers property. At the very least, this calls into question the City's general philosophy that properties axe "benefited" by any storm sewer improvements afEecting subject properties. Another area where the Appellant/Landowners take issue with the City of Eagan's Appraiser's Report is Mr. Dwyer's failure to consider either 20,000 square feet of future ponding right-of-way or twenty percent future right-of-way for road or other purposes in arrivinq at his estimate 4&f the benefits to the property as a result of the Storm Sewer Project 444R. For example, Mr. Dwyer states in his report section titled "Land Value Estimate - After" that: "Therefore, after a thorough analysis of all factors, it is the opinion of your appraiser that an increment in value of $1,500.09 per acre can be substantiated for the su6ject ptoperty in the after situation. This wonld indicate a value as follows: 6.36 acres at $17,500.09 per acre equals $111,500.00." in this calculatinn, Mr. Dwyer gives no consideration to the future right-of-way of twenty percent listed in the Final Assessment Roll figures foz the DesLauriers property and also no consideration to 6 the originally indicated additional right-of-way of 20,000 square feet for ponding purposes (as contained in the Original Assessment Roll figures). To this extent then, Mr. Dwyer's Appraisal Report is invalid. The City's own actions are also called into question on this specific issue, in that they expressly stated that "proper credits were applied for potential future right-of-way and easement dedications if and when the property should ever develop." Exhibit containing special assessment committee meeting staff recommendations on the DesLauriers parcel. Of further note is the fact that in the final assessment roll figures, any notation as to future right-of-way for ponding purposes of 20,009 square feet is deleted; the result is an increase in assessable area and thus an increase in the total assessment figure for the DesLauriers. A ponding requirement of 4,2 acze feet or approximately 2 acres of area on the present topography of the nesLauriers property is now already required, and yet the Appellant/Landowners have not been given credit for this on their total assessment. II. ASSESSMENTS NON-UNIFORM The assessment of the DesLauriers proper.ty is not uniform in comparison with adjacent landowners being assessed for Storm Sewer Project 444R. A glance down the page af the exhibit titled "Einal Assessment Roll Holland Lake Area Outlet Project No. 444" indicates that the pesLauriers property, far from being the largest piece of property, is assessed in the highest amount. The Court will note that some of the parcels have been given "large lot" credits in 7 exchange for utility easements while some have not. The fact is that a numUer of larger paccels under similar circumstances aee receiving a total assessment amount far less than the DesLauriers parcel. And, the DesLauriecs' are forced to put up with an unsightly lift station right at the entrance to their property. No adequate reason has been put forth by the City, as required by law, to justify this large disparity in the total assessment figures. Lundexberg vs. City of St. Peter, 398 N.W.2d 579 (Minn. App. 1986). CONCLUSION The Appellants' property has not been benefited by the Storm Sewer Project 444R in an amount to or greater than $9,500.00, and in fact it has been damaged consider.ably by this pzoject. The Appellant/Landowners request the Court to enter an Order determining that there has been no benefit to the su6ject property as a result of the Storm Sewer Project No. 444R, or in the alternative, to set a limit to the assessment far lower than the current total assessment figure of $9,500.00. Dated: May 11, 1989. Respectfully submitted, BIBUS AND LARSON, LAW FIRM c--? 420i' ?o By . ? Thomas W. ibus 8114) Attorney for Appellants P. 0. Eox 2838 6575 Cahill Avenue East Invec Grove Heights, MN 55075 (612) 457-2046 8 . - -C o S QVI ?, ?. ? °? '( ?j • ,? ? 6A J STATE OF MINNESOTII DISTRICT COURT COUN'PY OF D71KOT11 FIRST JUDICIAL DISTRICT -------------------------------------------------------------- CITY OF EAGAN, a Municipal corporation, Petitioner/Respondent, vs. NOTICE OF APPEAL AS TO THE DesLAURIERS PARCEL Martin DesLauriers and Marie S (Parcel 10=02600=0011-52)?-i DesLauriers, husband and wife, ' -- - - - -- APPellants. IN THE MATTER OF THE nSSESSMENT UPON THE SUBJECT PROPERTY FOR THE HOLLnND L11KE TRUNK STORM SEWER PROJECT 444R. OWNERS: MnRTIN AND MARIE DESLAURIERS, HUSBAND AND WIFE. T0: THE CLERK OF THE CITY OF EAGAN: ROGER S11MES, Clerk of the above-named District Court; HAUGE, EIDE & KELLER, P.A., Water View Office Tower, Suite 303, 1200 Yankee Doodle Road, Eagan, Minnesota 55123, attorneys for the City of Eagan on this and related condemnation matter (District Court file no. 10262E3. PLEASE T11KE NOTICE that the appellants herein, to wit: Martin DesLauriers and Marie DesLauriers, husband and wife, hereby appeal to the above-named District Cour.t from the special assessment levied upon said property in the amount of $9,500.00 as approved by the City Council on October 6, 1988. Appellants' objections to the special assessment are on the following grounds: 1. The property is improperly assessed and is not based upon the benefits received. 2. The assessment amount is gr.ossly excessive and not in accordance with current zoning and use of the property. 3. No deduction has been made for future right of way for ponding or flooding purposes. WHEREFORE, the Appellants pray that: l. Tlie special assessment not be confirmed; and that, 2. The assessment be set aside and there be a reassessment as provided in M.S. 429.071, Subd. 2. Dated: /ve-z? ev, / 9 ?'OP BIBUS & LAR ON LAW FIR M B y : /?-t - q`! Thomas W. Bibus, ID#8114 nttorney £or Appellants P. 0. Box 2038 6575 Cahill Avenue Inver Grove Heights, MN 55075 (612) 457-2046 J Bonestroo, Rosene, Anderlik & Associates, Inc. O 2335 W. Trunk Highway 36 St. Paul, MN 55113 612•636-4600 Englneers & Architects October 21, 1986 Mr, Mertin DeeLauriere 1031 Cliff Road ? Lagan, MN 55122 Be: Holland Lake Lift Station Project No. 444 E&&&ri, 'PIN File No, 49355 Dear Martin, `^ OQ V ill Q??w Ouo G &.nnuw. P E Nunrn W Nwrn+. Y.t lwryAC, A?Wer41.Yl. NruJ/md A, l mihr.?. P E MaM1m? L ivrnn, Y.1 611 S2 G/rnn R. Cuw. F G Ani?A LwJun Y! 1 numw G Nryn. Y f. R. nma W hw", P[ N?rtG Sc"A" nr,PG .,?,.,,, ?., .,.,...,?. ,•, rw?ww c. a?.r?.e? r r. Jflry A. BUY?Jun. Y l. Mur4 A. /luiuon, Y ! 1rvf K £1rld. !? F MuAuH T kumnwnn, Pt x,.e,•„ x rr.l?.,n. r L IhrdU Lu?A?w, P! lnur. K' Wuu..•?, Pt MnnuelC lrmn Yf Aunn f., Wrtln. l'J lurnr? k Mulmrl. P t Arnnnh /' nnJu?.,x P F ArulrA bwhmmo? I'! Mu'i N. )fidp. Y f Nobrr C kuuex, n / • lhoixu? t .InMu., i• I .4 un L Yuunx. 1' I Churlre A beA?er? Lru Af PowrbAy llurlon M Wmn .lurun M. tbr.lm You have requeeted a letter confirming the potential future ponding volume to be required on your property in the event that you or a future owner decides to develop the property. The Maeter Storm Sever Plan for many yeare hae anticipated that the low land an ypur property would be dedicated for ponding when and if the land wae de- veloped. Baeed upon the moet recent plan, iC is anticipated that 4.2 ac. ft. of etorage vill be the total volume required on your propecty. The location of thie atorage is normally in the lowea[ portion of the existing topography. However, if development of the land indicatea that regrading would be more desirable, thie volume can be placed in other locatioas on the property. It is also poesible that development of adjacent parcels within the drainage area could reduce thie total volume required if atorage is provided some place elee in the drainage area. In eny event, iC is anticipated that the total volume required would not exceed 4.2 ac. ft. As we indicated in our diecueaione with you, we will be pleaaed to meet with any potential purchaeer of your property to explain the preeent and future re- quiremente which would be anticipated for the development of thie property. Please call if there are further queetions. Yours very truly, SONSSTR00, RDSENE, ANDERLIK & ASSOCIATES, INC. Robert W. Roaene RWR:li V"' cc: Mr. Tom Colbert Mr. Paul Hauge, Atty. 30 Year 0065e Anniversary oF eagan 3830 PILOT KNOB ROAD, P.O BOX 21199 _ BFA BLOMQUISi EAGAId, MINNESOTA 55121 MO+'O' PHONE (612) 454-8100 1HOMA5 EGAN JAMES A SMITH VIC ELLISON 5eptember 21, ].987 7H?DOR?embersER iHOMAS HEDGES Gly Atlminclrator MARTIN & MARIE DESLAURIES EUGENE VAN OVERBEKE Ciry Clerk 1031 CLIFF ROAD EAGAN MN 55122 55123 Re: Project #444R, Parcel #10-02600-011-52 Special Assessment Objection Dear Mr. & Mrs. DesLauries: At the formal public hearinq before the City Council, you submitted a written objection to the proposed final assessments against your property for the improvements associated with that project. Subsequently, the Council deleted your property from the final assessment roll that was formally adopted and certified to the County for certification onto the tax rolls. Your objection was then referred to the Special Assessment Committee for an in-depth review of the improvements, the related benefit to your property and the proposed assessments. This Special Assessment Committee is comprised of two Council members, two Planning Commission members and three residents of the community. After their review, they will forward a recommendation to the City Council for formal consideration of final adoption of the proposed assessments. The Council's consideration of the Special Assessment Committee's recommendations will be held at a future formal public hearing and mailed notification similar to the public hearing process you recently completed. While there is no definitive schedule for the Special Assessment Committee meetings, it is i3ot anticipated that this item will come before that Committee any sooner than April of next year. In the interim, the City will be performing a formal appraisal of your property to verify that the benefit to your property through increased value was at least equal to the amount of the proposed assessments. This appraisal process will be coordinated through our City Attorney's office during the ensuing months. When the Special Assessment Committee meeting has heen scheduled, you will be so notified in writing with a request to provide any iHE LONE OAK TREE. .. THE SYMBOI OF STRENGTH AND GROWfH IN OUR COMMl1NI1V September 21, 1987 Page 2 additional information or appraisals you may have compiled in the interim. Once all this information has been gathered , a staff report will be prepared for the Committee meeting with a copy forwarded to your attention prior to that meeting. In the interim, this special assessment will continue to be listed as a"pending" assessment but there will be no interest accrued beyond the amounts proposed at the time of the recent final assessment hearing. IE you have any other questions regarding this procedure or your assessment, please feel free to contact me at your convenience. Si rely, ? ?.e'rn.a.a-r Thomas A. Colber , .E. Director of Public Works TAC/jj cc: Paul Hauge, City Attorney Deanna Kivi, Special Assessment Clerk . Page 20/CITY COUNCIL MEETING MINUTES October 6, 1988 McCrea moved, Egan seCOnded, the tation to close the public hearing and reaffirm the oi:aginal fina3:;:assessment roll for Project 476 (Wescott Road) as it pectains to.paccel 10-01400-030-53 ann authorize its certification-tounty. All voted in favor. PRQ7ECT 444R, HOLLAND LAKE STORM SEWER (PARCEL 10-02600-011-52) Public Works Director Tom Colbert stated that the improvement that was installed hanole$_the.storm water runoff fzom the subject property through the City??::::triink;;starm sewer system all the way to the biinnesota River. He furEher,:staEea::,proper ctedits were applie6 for potential future right-of-way and easement dedications if and when the property should ever develop.:::He stated it is properly assessed in accordance with City:;p.olicyes and procedures and the current zoning and use of.th.e:.:propex:ty:: However, due to the fact that the City's appraisal report indicaCed that the increased market value is less than the proposed assessments, it was staff's recommennation that the proposed final assessment be reduced to $9,500.00. Martin DesLauriers objected to any assessment as he stated there was no benefit to his proger.ty. He stated his property had lost value. He distributed a handti:ut:<..to the Council and showed the location. He stated he felt the:::pt:o.perty would be flooded and further explained reasons for his obj:ection, 'He.requested deferment until the holding pond was defined. Mr. Colbert stated thei:`starm`sewer plan locates 340 drainage areas. He further stated the City was not in need of it now, but that upon saturation it may be needed. He stated the plan would be reviseci in the future but he did not know what the future woula bring. He outlined the benefit to DesLauriers' property. Councilmember Egan questioned how the assessment would be abated. Mr. Colbert stated by agreement. He stated the r.eaI;:::isanesa:as:-:how much of the area shoula be included and that at tHe?::.pr:esetit;tzr?e, he was uncertain of that amount. He stated he would need :to see,..the development proposal and he would prefer to postpone, not::::abate:< M[. DesLauziexs stated it w8s not:.:acceptable to him to 3ust postpone the matter. Much discussion was held regarding the ponding. Councilmember Egan questioned that if the City would abate, if there would be a need for a ponding area. City Attorney Jim Sheldon stated i'ktere were two issues: 1. Benefit to the 2. Acguiring the ponding'easement._:: COtV oF czagnn 3830 PILOT KNOB ROAD, P.O BOX 21199 V1C ELLISON EAGAN, MINNESOTA 55121 M?r PHONE: (612) 454-8100 niOnMS EGAN DAVID K, GUSTAFSON PAMEIA MCCREA September 21. 198$ iHEODOREWACHTER Counal Members n+oMus HEOCEs GtyAdmimsfrolor EUGENE VAN OVERBEKE MR & MRS MARTIN DESLAURIERS ciNaen 1031 CLIFF ROAD EAGAN MN 55123 Re: Parcel 10-02600-011-52 Project 444R, Special Assessment Objection Dear Mr. & Mrs. Deslauries: On June 30, the Special Assessment Committee reviewed the formal objections that you submitted at the original final assessment hearing held on September 1, 1987, pertaining to the trunk area storm sewer assessments of $10,965,20 associated with Project 444R, Holland Lake Trunk Storm Sewer. Enclosed you will find a copy of the portion of the minutes pertaining to your objection. You will note that the Committee recommended that the assessment be reduced to $9,500 in compliance with the special appraisal report performed by the City of Eagan pertaining to this assessment and your objection. The Committee's comments and recommendations are being forwarded to the City Council for formal consideration on Thursday, October 6, 1988. If you have any additional information that you would like to have considered by the Council, please provide it to my attention no later than October 3 so that it can be distributed to the Council for their timely review. Sincerely, Pv'.o-."'`i-`+s Thomas A. Colbert, P.E. Director of Public Works TAC/ jj cc: Deanna Kivi, Special Assessment Cierk Enclosure THE LONE OAK TREE.. THE SYMBOL OF STRENGTH AND GROYVTH IN OUR COMMUNItt NOTICE OF ASSESSMENT HEARING CITY OF EAGAN DA%OTA COIINTY, MMpggOT6 NOTICE IS HEREBY GIVEN, that the City Council of the City of Eagan, Dakota County, Minnesota, will meet at the Eagan Municipal Center located at 3830 Pilot Knob Road, in said City on October 6, 1988, at 7:00 p.m. to consider the proposed assessment of Parcel 0 10-02600-011-52 for Projeet # 444R in Eagan. The proposed area to be assessed is described in the assessment roll on file with the City Clerk in his office, whieh roll is open to public inspeetion. Written or oral ohjections will be considered at the public hearing. An owner may appeal an assessment to distriet court pursuant to M.S.A. 429.081 by serving notice of the appeal upon the Mayor or Clerk of the City of Eagan?within thirty (30) days after the adoption of the assessment and filing such notice with the District Court oP Dakota County wlthin ten (10) days after service upon the Mayor or Clerk. Further information relating to these assessments may be obtained from the Special Assessment Division of the Finance Department and any questions should be directed to that Division. Dated: September 22, 1988 ? V E J anOverbeke City lerk, Eagan ;.? i SPECIAI. ASSESSIDii' COhYNITTEE MINUI'ES .IUNE 30, 1988 PAGE 3 Egan moved, Colton seeonded the motian to affirm the proposed final assessmenC subject to the available reduction tmder public Policy 86-3, i£ and only if, Mr. Bratland executes the appropriate docwnents required uzxler the policy. All troted in favor. WILLIAMS & T.ARI]E ].Si' ADDITION STORM SE4JER KGLMGR BRATCADID Public works AirecCOr Tom Colbert stated that imder Project 450 the City installed sanitary sewer, water main and stiorm sewer servi.ces to service the Williams & TaRue 1sC and 2nd-Additions which are located adjacenC Co ard wesC of Mr. BraClanci's properCy. The storm sewer improvement provides drainage to Mr. Sratland's properCy. Mr. Bratlancl had never been assessed for a trumk area storm sewer improvement. Of the 4.75 acres of properCy owned by Mr. Sratlarid and after applying the "large lot credit" urder SpeciaL Assessment Policy 82-4, the residual neC assessable area was reduced Co 1.89 acres and assessed at the single-family residential/ agrzcultural rate. The property b2ne£its by having a controlled storm sewer outlet provided for the pording area that incorporates a portion of the Bratland property. Merk].ey moved, Egan secocxled the mota.on eo reaffirm the original assessment with the application of Speci.al AssessmEnt Polfcy 82-4. All voted in favor. FiOLLADID LAKE TRUNK STORM SEWGR MATtTIN DES LAURTERS that the increased market value is less than the proposed assessment ard that the SCaff's recomnendation is that the proposed final assessment be reduced ti6 $9,500.00,per the appraisal. Public Works Dzrector Tom Colbert sCaCed ChaC under Project 444R the City installed a compleac tx7mk storm sewer system generally located along C1iff road. It pzwided for the installatzon of a sCorn sewer li£t station on Mr. Desiauriers' property providfng a controlled outlet strucCwre £or the pvnd locaCed adjacent to and east of AesLauriers' properCy. The City's appraisal report performad by Dahlen & Dwyer, Inc. indicates A Zekter was sutmitted by MarCin and Marie DesLauriers indicaCing thaC Chey objer:,ed Co the assessment but would he out of tam on the night of the meeting. Tt is the lardowmers' posiCion that the project did noC provide arry benefits to Cheir pzroperty. Public Works DirecCOr Ton C?1berC indicated that DesLauriers were not eligible far the "large 1ot credit" because their parcel was larger Chan 5 acres. Mr. besLauriers was not eligi6le foY the "large lpt credit" since it can be anCicipaCed Chat the Iot wou7.d be subdivided at a fuCUre daCe. There was a credit given for future righC--o£-way acxi easement dedzcations. Ttaaddell asked whether or not there was a credit given far the lift station. Colhert indicated tt,at the lift sCaCian had just been acquired Chrough condercmation process ?. ti?? SPECIAL ASSESSMEKI' CCNMITTEE MIiv'ITITS JLTNE 30, 1988 PAGE 4 and that the City now conerolled the lift station and that no crediC was chen afforded Co Mr. AesLauriers. Egan asked Colbert to caamnt on the assertion by DesLauriers that his property weuld be used as a holding pond in cormection with the li£t station an3 the culvert cormecCing the pond to the easC of the DesLauriers property. Public Works Dixector CoZbert stated that the Staff arid the consulting engineers disagreed with AesLauriers an3 that afCer the "super storms" of July, 1987, that the water level in the poixl to the east of the DesLauriers properCy did not raise to a level thaC it wouid back-up through the culvert to the DesLauriers property. Anne Marie nestauriers was present on behalf o£ the property otimer. Egan moved, Colton seconded, the motion to modi£y the original assessrrent to $9,500.00. AL1 voted in favor. The meeCing was then called to recess by Chairpezson 'Itaaddell. Zhe Special Assessment Cortmittee was recoxrvened at 6:30 p.m. PARCEL 10-03000-010-29/HERB AC»LMMAANN Public Works Director Tan Colbert sCated thaC under Project 460A the City provided £or the reconstruction o£ Nicols Road fran an old rural Coimty road ditch to an urban street section wiCh curb and gutter and trailways. T'he property currently carries a comroerciai zoning under the Limited Business classificaCion. Its use is tmder-util.ized by the presence of an existing single family dwelling. In accordance with SpeciaL Assessment Policy 82-2 (Assessments Against Lard Whose Present Use is Different from the Llzrrent Underlying 'Loni.r?,) the property owner could reduce the proposed assessments Co $9,112.50 subject Co the execuCion of the appropriate agreemenCS in accordance with the policy. Tom Scott, an attorney at 3460 Washingtcm Drive, Eagan, MN, appeared on beha7.f of the Adelmatms. Nrr. ScoCt indicaCed that he beiieved the present zoning on the property was R-4. public Works 17irecCOr Colbert indicaCed that Mr. ScoCC was correct. htr. ScotC indicated that the Adelnarnls were the only re?idents an thaC particular stretCh of Nicols Road and that iCS present use-would be R--1. Mr. ScoCC objected to the special assessments being at the R--? -;;lassifi.caCian. Mr. ScoCt i.ndi.caCed that under the present R-1 zoning thaC rnere shouid noC be arry amount included in the assessmenCs for a trailway buC that because it was bein,, assessed urder the R-4 zoning the cost was being borne by the AdeZmanns. Mr. ScatC irxlicaCed Chat he believed that the Adelmanns were the only residenCS being assessed at the higher rate in connectian with this project. Mr. Scott indicaced ehat his o6jecCions were 6ased on his belief that the properCy had noti been , benefiCCed by the $24,000.00 assessmenC. Mr. ScpCC submi.tted a J.etter fr«n gay Connel],y, a realtor and appraiser, sCaCirg that there has been little if any increase in the value o£ the property due to the project. P:--:, . 0 REcEIvED €ED 2 ? ??/ ":7a- 74- i' 7-1 .? f ? / Gpe 0G L) Y r ? SGG e2 C?5 ? ssi ?/?° s??1)4z ,'ZGrIG 7' i 6 Martin ft Marie Des LauriOrs M?, qtimna 85205 PROPERTY TAX STATEMENT ' 1989 ?? ? ? ?? ? V , ? ?? /?[f coveRNMeN-r ceNTER ,n HASTINGS, MN 55033 ?•.s...w:,:?.»?.l:?ho'?!s«,'ab%.M' Y.?:aa w?.'??'??..?`i'.?w?'.3{'"tc ?? ?? Y . THE STATE PAVS AtDS TO LOCAL UNITS OF t DAKOTA COUNTY TREASUREF 36VERN0IENT TO RcDUCE VOUR PROP ERTV TAX F .` .., . •-. . ? •:P^..i.?.:,.} ' ? ? • TA YOUR .:_.. ?.::,.?.: >.. ,:r ..?.c .,..c.c:.e?[7i,Y:ii?.:i:s'`.?'lw??:si?G'S':?? a.''.r.,..''? PROPERTY TAX REDUCTION FROM2 TAX RELIEF S 838 75 PROVERTYIDEN?liiCAT10N PflOPERTYHOMESTEHDED SCHOOL' LOAN s:;? rt - _-------- - CODE W/5 ? , . ?°• '? ' e [ - - FSOi .. ?n1'M1t_C_?S?_ ?r.ab":;-??.i? ?IST PCAT L?T BLN JAA 2. 19890F JUNE 1. 1988 DIST ? CODE 1 r^_.:? t T ?,'"m :??,ip •? ,?,<- . . R { ` 10 02600 011 52 ^ c7?TF' YES 196 G ° ^r ' ` o.00 ? ? cpUNTY 9'I7 O1 ' SSTAX ESTMAtED MAFKET VALIIE GRO CI+PACITY NEWIMPFOVEMENTS , ?or.wnonmr ?=`? . 73 900 __"_'*STOWNSHIPORC!TY o?,; S.. ^ HOOL DISTRICT 00 ;. 715 0 4 76728 • 2, . 0 ? ELIGI ' "_'__" BLE FOR A flEFUND. TO RNC, CJT Ir'vGJ . , e aTFICT TN=_P TFXIN^ .? 01" y O' ' =- c! i3!3LE FOF THE MINNESOTA PROPERTY TAX REFUND.'. ;6Z ' 6 ? AND y SPECIAL PROPERTY TAX REFUND. A 1' USIN3 THE 1.4 RLL J• cJ -y ' - `isc;.LoisPaF?av ?•r _ c. - 2??: ?cs:: o?: un='"ye-r_od.- ?.? MENT OISi e i ^ O . OO O. OO ? p j ^ i?:r FI.'.J ':T° P"'F^, W 0 0 : W T=-_ RSHEC 4,432.00 725.00t'?,.---_- --_-_-_-- ----O-.DO- ? :: ' :aF : ? ?a 4 K? ? y ?' ? eTAzse=oaecHor:s ------- wddv .'nu-? wer '`h :w. a, t- o - ^-'?v:: ? - ? +* +i - - :?: EOITS VJHI : YOUR TAX - N REDII ^ -4..432._DO_ i r . ?. ±? ,r. _ . , ?c.easl. : S:p.rz:,. -.:,.•.: a s r.... . ? . ?a? ,n s :_ a . a . . .are. rw .r - ,R . , C IF THIS 80% IS CHECKED .- m YOUDWEDEUNQUENT ?f ^ STATE PAIC AG91GL"?TL1RhL CREUIt 00 0 i ? TAXEAN?MA? NOT . ? F o?, MARTIN DESLAURIERS qpPLY FOH THE E STHTE P41D Hp1.SESicSD GFEGIT ,aaorearrTwxaecuNOS 725.00 i FN G AG PP,ESeRVE CREOR 0.00 ' F= 1031 CLIFF RD =oisnseacaeort l R ? T FTEF CREDI75 i ? AY. A 1C 3? 7_OZ_D 0 ' EAGAN MN 551 L3 ' '?"• SPCCIAL ASSESSMcMS .__.------ , i ? A aau401anL 633 . 33 e wTEFESr 942.03 a I A ? MARTIN DESLAURIERS 18 E . . 1031 CLIFF RD ,?: .? ??• • : „ ? _ _ ? i F : ft sc.r :t ,-f ?r. . ; : W ? , 2 641 18 EAGAN MN 55123 = . ' -*1 - _ eNTS 1031 CLIFF RD 1798 SSTK 444 1,575.36 EAGAN MN 55123 k?. OF 3830 PoLOT KNOB ROAD. P.O. BOX 27199 EA6AN, MINNESOTA 55121 VFIONE: (612) 454-8100 March 6, 1989 MR & MRS MARTZN DESLAURIERS 5459 E HERMOSA VISTA MASA ARIZONA 85205 Re: - 86=9Y1=5'Z-J7 Project 444R-,Special Assessment Objection/Appeal Dear Mr. & Mrs. DesLauriers: \AC ELLISON MUr*N ?K)MAS EGiNI U4V1D K GUSTAfSON PPMEtA McCRfA THEOOORE WACHfER Carci Marnbers IViOlAlS HEDGES CRYPt4*JNSkalor EUGENE VAN OVEfffiEKE cm c? On February 27, I received a letter from you expressing your shock that the amount of the special assessment for the above- referenced project was certified to your property tax statement while you are appealing that assessment to District Court. As you zecall, on October 6, 1988, after considerable discussion and review of the facts and information pertaining to your original objection, the City Council adopted the special assessment and authorized its certification to t'he County. Subsequent to that action, your attorney filed a Notice of Appeal dated November 4, 1988, to District Court regarding this assessment. To this date, the City has not received any judicial direction or restraining order compelling us to remove the special assessment that was properly adopted by Council action and certified to your property. By the mere fact of filing an appeal with District Court does not remove a special assessment. It requires the Court's determination that the assessment in fact was improper. This has not yet been detezmined. I do not believe you have to hire an attorney matter as you have already done so by proceeding of Appeal to District Court. Therefore, the remain an obligation of your property until th formally directed to the contrary. I hope this information helps clarify the issue the special assessment was certified to your tax to handle this with your Notice assessment will : City has been and explain why statement. Sincer , ec: Mayor Vic Ellison ?? Thomas L. Hedges, City Administrator Gene VanOverbeke, Director of Finance omas A. Colbert, P.E. Jim Sheldon, City Attorney Director of Public Works TAC/jj THE LONE OAK TREE. ..THE SVMBOI OF STRENGTH AND GROWTH IN OUR COMMUNIiY Lj' ? ?• 3 ?09?• `? ? \\AN` \e°? C)n ST11TE OI' MINNESOTII S, y,96 UISTRICT COURT COUN'PY OF UAKO'1'A kF1RS'P .IUb1C1AL DISTRICI' -------------------------------------------------------------- CI'1'Y OF EAGAN, a Municipal corporation, Petitioner/Respondent, vs. NO'I'ICP•. OF l1PPEAL AS TO TI113 Ues1.AURIERS PARCEL Martin llesLauriers and Marie (Parcel 10-02600-0011-52) DesLauriers, husband and wife, 1lppellants. IN THE MATTER OF THE ASSESSMENT UFON TFiC SUBJECT PROPERTY FOR THE EiOLLAND LAKE TRUNK STORM SEWER PROJECT 444R. OWNERS: MnRTIN AND M11RIE DESLAURIERS, FIUSBIIND AND WIFE. TO: THE CLERK OF THE CITY OF E11GAN: ROGER SAMES, Clerk of the above-named District Court; H11UGE, EIDE & KELLER, P.A., Water View Office Tower, Suite 303, 1200 Yankee Doodle Road, Eagan, Minnesota 55123, attorneys for the City of Eagan on this and related condemnation matter (District Court file no. 102628. PLEASE TF1KE NOTICE that the appellants herein, to wit: Martin DesLauriers and Marie DesLauriers, liusbancl and wife, hereby appeal to the above-named District C'ourt Prom the special assessment levied upwi said property in the amount of $9,500.00 as approved by the City Council on October 6, 1988. nppellants' objections to the special assessment are on the following grounds: 1. The property is improperly assessed and is not based ?pon the benefits received. 2. The assessment amount is grossly excessive and not in accordance with current zoning and use of the property. 3. No deduction has been made for future right of way for ponding or flooding purposes. WAEREFORE, the Appellants pray that: 1. Tlie special assessment not be confirmecl; and that, 2. 7'he assessment be set aside and there be a reassessment as provided in M.S. 429.071, Subd. 2. Dated: er / 'u'k BIBUS & LARSON LAW FIRM By: qv ? Thomas W. Ribus, IDN8114 nttorney for 1lppellants P. O. Box 2038 6575 Cahill Avenue Inver Grove Heights, MN 55075 (612) 457-2046 r sity oF eegan 9830 PROT KNOB ROAD. P.O. BOl( 21199 yC gisqN EAGAN. MiNNESOTA 55121 MOW PViONE (612) 454-8100 7HOMAS EGAN MVID K GUSfAiSON September 21. 1988 PANEIA LACCREA nffoooREwacHU cw,d MWnbn AaMnsHMCEs cer? ?E ?? MR & MRS MARTIN DESLAURIERS ?? 1031 CLIFF ROAD EAGAN MN 55123 - Re: Parcel 10-02600-011-52 pco3ect 444R.'Special Aasessment Objection Dear Mr. & Mrs. I3ealauries: On June 30, the Special Assessment Committee reviewed the formal objections that you submitted at the original final assessment hearing held on September 1, 1987, pertaining to the trunk area storm sewer assessments of $10,965.20 associated with Project 444R, Holland Lake Trunk Storm Sewer. Enclosed you wi11 find a copy of the portion of the minutes pertaining to your objection. You will note that the Committee recommended that the assessment be reduced to $9,500 in compliance with the special appraisal report performed by the City of Eagan pertaining to this assessment and your objection. The Committee's comments and recommendations are being forwarded to the City Council for formal consideration on Thursday, October 6, 1988. If you have any additional information that you would like to have considered by the Council, please provide it to my attention no later than October 3 so that it can be distributed to the Council for their timely review. Sincerely, LO7Gto? Thomas A. Colbert, P.E. Director of Public Works TAC/jj cc: Deanna Kivi, Special Assessment Clerk Enclosure THE LONF OAK TREE. .THE SYMBOL OF SiRENGTH AND GRONRH IN WR COMMUtrIiY • • SG.rilW lfJJG34y,y KA'i'LLiLLi `IYWIGJ JtA+IE 30, 1988 PAGE 3 Egan mDved, Co1ton secanded the wotion to affi:m the proposed ffnal assessnent subject to the available redtactim tmder Public Polity 86-3, i£ and anly if, Mr. Bratland executes the appiropriate docimec?ts required under the pplicy. All, voted in favor. WILLIAMS & LARLIE 15T AWITI@i SM SOIER KELMM BdtATLAPID Fublic works Airector Tan Colbert stated that uasder Pro3ect 454 the City installed sanitary sewer, water maSn and storm sewer services to service the Willians & LaRue Ist and 2nd Additions which are located adjacerit to ard west of Mr. Bratlarxi's pxoperty. Zhe storm sewer improvenent pravides drainage to Mr. Bratland's property. Mk. Sratland had never been assessed far a tnmk area storm sewer impravement. Of the 4.75 acres of property owned by Mr. Bratlard and after applying the "Isrge lot credit" under Special Assessment Paliey 62J4, the residual net assessable area was reduced to 1.89 acres and assessed at the single-family residential/ agrzcultural rate. 1he property beaefits by having a con[rolled storm sewer outlet pmvided for the pording area that ircorporates a portion of the Bratlard property. Merkley naved, Fgan seconded Che motian to reaffirm Che original assessment with Che apglication of Speci.al Assessment Policy 82-4. All voted in fawr. mmLW"Im? $[DW ?O.LJ.?? 36i7 ?S Public Works Director Tom Colbert sCated ChaC vnder Project 444R the City installed a complex tnask storm sewer system generally located aZong Cliff road. It pxavided for Che installation of a sCoxm sewer lift station an Mr. Deslatwiers' pcnperty providing a controlled outlet strvcture for the pond locaCed adjacent to and east of DesLauriers' property. The City's appraisal report perfoxned by Dahlen & Dwyer, Inc. itidicates that the increased market vaiue is less than the proposed assessment aKl that the SCaff's reccmnendetion is that the proposed £inal assessment be reduced i36 $9,500.00.per the appraisal. A letter- was submitted by MarCin end Marie DesLauriers ixdicatfng thaC they objected to the assessment but would be out of town on the night of the meetiTg. TC is the landownexs' position that the project did not provide airy benefits to their property. Public Warks Director Taa Colbert indicated that Deslatsiers were not eligible far the "large lot credit" because their paYCe1, was larger tban 5 acres. tYr. DesLauriers was not eligihle for the "large.lot credit" since it car be anticipated thaC Che lot wail.d be subdivided at a future date. There was a credit given for fucure right-of-way and easemesst dedications. Twmddell asked whether or not there was a credit given far the lift station. Colhert indicated that the 11ft station had just been acquired Chrough candeamtion process John J. Klein 1495 Lone Oak Road Eagan, Minnesota 55121 May 19, 1989 Honorable Judge Thomas M. Murphy District Court First Judicial District Dakota County Government Center Hastings, Minnesota 55033 Re: Court File No. : C2-88-8935 Respondent's Closing Argument Brief Your Honar: Today, I received a copy of the hereinabove referenced brief, and after reading the second paragraph on Page 4, I am mighty angry at being called a liar. To prove the validity of my testimony, I am submitting pages from the City of Eagan's 1978 and 1984 Comprehensive Storm Sewer Plans which were prepared by Bonestro, Rosene, Anderlik, & Associates, Inc., Consulting Engineers for the City of Eagan. These plans were certified by Robert W. Rosene, a principal of that firm, and both plans were certified for approval by Thomas Colbert, Eagan's City Engineer, Rosene and Colbert testified contrary to the drainage and ponding figures in those reports. Appendix C, Pond Data, Page C-9 of the 1478 Report, shows clearly that there are 70 Tributary Acres which flow across the DesLauriers' property to Pond LP-51, and the "Storm Sewer Layout Map" shows that the Storm Water is directed under C]iff Road directly into Holland Lake, then westerly along the south side of Cliff Road. Appendix C, Pond Data, Page C-18 of the 1984 Report shows that previously only 70 acres flowed directly across the DesLauriers property. Under this new engineering plan, 2885 Tributary Acres have now been directed, by man-made means to LP-51, and now flow westerly along the southerly side of the DesLauriers property on the north side of Cliff Road. Table A, Pond Data, dated 5/16/86 clearly shows the Existing Level at the 867.7 foot elevation, and the Proposed HWL (High Water Level) to be at the 880 foot elevation, which I showed on the contour map at the trial to reveal the height at which the DesLauriers property is now potentially subjected to flooding under the City's new Storm Sewer Program. Your Honor, I submit these figures and maps from the City's own documents to support the validity of my testimony. I did not testify falsely at the trial! Thank you for your consideration of this matter. Sincerely, ? •- i John J. Klein cc: Thomas W. Bibus Joseph P. Earley Martin DesLauriers HAUGE, E3DE & KELLER, P.A. /7y n PAUL H. MAl10E ? JRttorneya at eLaw KEVIN W. EIDE TOWh CENTRE PROFESSIONAL BLDG., SU1TE 400 DAVIDG.KEl1ER ? 1260 YANKEE DOODLE ROAD oEerue.sa+NnD? EAGAN, MINNESOTA 55123-2201 TMO1`°^SP•LOWE (612) 456-9000 FAX: (612) 454-4292 RECEIVED ' P9AY 2 6 9989 May 29, 1989 Mr. Thomas Hedges City of Eagan Dear Tom: !v - vaGoo ' 0 [r-s2. Enclosed please find a copy of the decision received May 23, 1984 from the Court of Appeals in regard to the Appeal of Martin DesLauriers from the jury verdict of the City's Appeal of the Commissioner's Award in the condemnation of the lift station site foz Project 444R. We are pleased to advise you that the Court of Appeals affirmed the Trial Court's decision and jury verdict to reduce the Commissioner's Award of $60,000.00 to $16,000.00. It is my understanding that Mr. DesLauriers did deposit the difference between the $16,000.00 and the amount paid pursuant to the 3/4's deposit requirement for appeal with the Trial Court. We will request that Mr. Bibus, the Delauriers attorney, confirm our request that the Clerk of Court release those funds to the City of Eagan at the earliest possible date. Sincerely, DGK:jh Enclosure AAUGE, EIDE & RELLER, P.A. David G. Keller cc: I/Tnomas Colbert James Sheldon NOTICE: A4EDIA AN1,? COUNSEL AP.E PROHtB1TED FRO*d MP-K1NG - Tf-US Ot II3;ON OR Ofi:'LR P'?Ei?C ri IOR TO 12:01 A.M. ON :'f'.E FILE DATE This oDini4n..will-,Ds.,unr)ublished and inn. Stat. S 450A.08, subd. STATE OF MINNESOTA IN COURT OF APFEALS C3-88-2133 Dakota CoUnty City of Eagan, Respondent, vs. Martin DesLauriers, et al., Appellants. David Keller Town Centre Professional Bldg. 1260 Yankee Doodle Road, $200 Eagan, MN 55123-2210 Thomas W. Bibus P. O. Box 2038 6575 Cahill Avenue Inver Grove Heights, MN 55075 Filed May 23, 1989 Office of Apgellate Courts tleard, considered and decided by Short, Presiding Judge, Randall, ,7udge, and Kalitowski, Judge. RANDALL, Judge Randall, Judge U N P U B L I S H E D O P I N I O N EACTS Appellants Martin and Marie DesLauriers appeal a jury award for a permanent easement and consequential damages resulting from an action in eminent domain by the City of Eagan (respondent). The City of Eagan's Project 444R, expanding the existing sturm sewer system, was necessitated by development east and north of appellant's property and by the demand of Dakota County that storm water no longer flow into Holland Lake. Project 444R essentially blocked the natural drainage from appellants' r property into Holland Lake, established a holding pond on property east and adjacent to appellants' property, and established location and construction of a lift station on the southeast corner of appellants' property. In 1986, respondent commenced an action in eminent domain in Dakota County District Court for permanent and temporary easements for trunk storm sewer, ponding and lift station purposes over at least two parcels of land. The district court awarded respondent a permanent easement of approximately 2800 square feet (.064 acres) and a temporary construction easement of approximately 3800 sguare feet (.087 acres) for the construction of a lift station on appellants' property. A hearing was held before court-appointed commissioners. Their report awarded $60,000 to appellants with no part of the award apportioned to consequential damages. Respondent appealed this award, and a jury trial was held. Pursuant to a motion in limine, the trial court ruled that testimony would be limited to the petition of condemnation and to damages to the remaining parcel of land directly resulting from construction of the lift station. After the evidence was presented and after viewing appellants' property and the lift station, the jury awarded appellants $2000 for the permanent easement and $14,000 generai damages, far less than the commissioners' fiyure. The trial court denied appellants' motion for a new trial, and they appealed. -2- D E C I S I O N , Respondent moved in limine that the trial court restrict tesLimony to the petition of condemnation: a permanent easement for a 35-foot by 82-foot parcel in the southeast corner of appellants' property, and consequential damages which occurred to the remaining property as a direct result of this taking. "The question of whether land has been damaged so as to require condemnation is a question of law which the trial court must decide before submitting the damaqe question to the commissioners in the first instance." City of Mankato v. Hilgers, 313 N,W.2d 610, 612-13 (Minn. 1981). The commissioners' conclusion that the storm sewer project, not the .064 acre taking or the lift station construction, had a potential impact on approximately two acres was beyond the authority conferred by the condemnation petition. A trial court has appellate jurisdiction when reviewing a commissioners' award, and it has no authority to modify the condemnation petition at the appellate stage. Id. at 612-13. Therefore, the trial court properly restricted evidence to the petition for condemnation. Property uwners are entitled to just compensation for property taken for public use. Minn. Const. art. 1, § 13. Where only part of a tract is taken, landowners are entitled to compensation for loss to the remaining land. Victor Co. v. State, 290 Minn. 40, 44, 186 N.W.2d 168, 171 (1971). "In such a case, the measure oE damages is ordinarily the difference between the market value of the entire tract before the taking and the -3- . ' market value of what is left after the taking." Alexandria Lake ; Area Service Reyion v. Johnson, 295 N.W.2d 588, 590 (Minn. 1980). To deterrciine fair market value, the highest and best use of the proper[y and any competent evidence which legitimately bears on market value may be considered. Ramsey County v. Miller, 316 N.W.2d 917, 919 (Minn. 1982) (citations omitted). The jury heard testimony from appellants' appraiser who claimed the highest and best use of the 6.5 acre parcel would be a 15-lot subdivision. He estimated the loss of approx2mately two acres of potential development at $277,406. Appellant Martin DesLauriers, a real estate broker, testified the property's highest and best use was as a single family dwelling. He stated the fair market value was $225,000, and damages of $80,000-$100,000 had occurred due to potential ponding. Respondent's appraiser valued the taking and consequential damages for the permanent easement at $1000 and for the temporary easement at $150. The jury valued the taking at $2000 and damages at $14,000. The jury heard sharply conflicting otal testimony from appellants and the various experts. We aifirm acknowledging that when factual determinations dependent on conflicting oral testimony, great the factfinder. See Shymanski v. Nash, 312 Mii N.W.2d 854, 657 (1977) (weight and credibility testimony is generally for the jury). the jury verdict are largely deference is owed m. 304, 306, 251 of expert -4- F*? 1 It is not the appellate court's function to substitute its judgment for that of the jury. Cardinal Consulting Co. v. Circo Resorts, 297 N.W.2d 260, 265 (Minn. 1980). Our decision today does not impinge on appellants' future right to possible compensation if fiooding of the two-acre area occurs. For this, the remedy of inverse condemnation could be available to appellants. Wilson v. Ramacher, 352 N.W.2d 389, 394 (Minn. 1984). Affirmed. ry? -5- /,_-a,i-S? ?, _ n .?^ - P:llWARD R. McMENOMY LARRY S SF:VLRS(lN* JAMF,S N. SHN:i.DON J.PATRICK WILCOX* TtiRLNCE Y UUHKIN MICHAb;L G. ?OUGHERTY REIDJ.HANSEN M1CHAh:I. N: MOLF:NDA** 'ALSOI.IC6NtiP;D fV IOWA *"A[SO IdCHNSA:U 1N WLSCONfiIN {AISU LICIiNSh;f17N NEBRASRA .7une 22, 1989 A PROFFSS[ONAL A530CIATION ATTpANti'S AT LAW 0 REPLY TO: 4300 WF.ST t47TH 3TREE7' Y O BOX 29329 APl'I.E \'ALLEY, MINNE30TA 55124 1'EI.Eb'AX NUMBER 4323180 (612) 9a2a1ss ? REPLY TO. 144W SOUTH ROHERT TRAIL ROSEMOUNT, MINNESOTA 560fi8 (612) 4231165 Deanna Kivi Eagan City Hall 3830 Pilot Knob Road Box 21199 Eagan, Minnesota 55121 Re: DesLauriers Assessment Appeal Qur File No.: 206-6050 Dear Deanna: 17 42 PAUL1J J. STIk:R PATRICK W.STP:WART KFNIN P. CAR20LL Kh.NNN.1H R HALL ? SCO1"P D. JOI-INSTON} JOSEYH P EARLLY ? MARY i. GOLIKN: MICHAliL C. McCANN OF COUN9A:L . L'C?.?(. aYC- Gk..?• JpHN k WKF:LlCH Per our telephone conversatian on June 21, 1989, I am enclosing a copy of the Order for Judgment in the Eagan vs. pesLauriers Assessment Appeal. The Court has ruled that the DesLaurier progerty (Parcel 10-2600-0011-52) has not benefited hy the storm sewer installation and that the property should not be assessed for Project 444R. I am also enclosing a copy of the Special Assessments Input Form showing the original assessment amount to be $9,500.00. The City should request that the County delete this amount from their assessment rolls. I have also been informed by the DesLauriers' Attorney that they have already made their first payment on this assessment. The City should also refund the amount of this first payment. Please contact me with any further questions or concerns, Sincerely, M MENOMY & SEVERSON, P.A. J se h P. Earley JP /dms Enclosure cc: Tom Hedges, McMENOMY 8L SEVERSON Eagan City Administrator Equal Opportunity/Attirmative Aclion Employer BPECIAL A88E813MENTB INPUT FORM - AUOITOR ?c• ?r..?' ? , - sr?-tauiege I ?`( nrs?ia-oisr I c, eec-YEnx ?%?f ?, --- --- --?---- ? E'IRST YEM ItlrO itEGULAR 2NT•L)`G U p TOTAL ASSESStFSn .vity X MU nssUsieVr c-ehaescs _ oectNOUerrr aMuars ? ASSESSHQ{P UPDATE ADD/UPDATE PARCELS Divislon IlJCE2m vo10 r 1 j5a.1 17.`1R1 1."' 1... 1 p I ncrza, A. - 1v3d C - Chanqe 0 - Deletc P - Print • boolcnhe e t O - Old Parcel (dlvision) H - NeW Parcel (division) DEF CUDE S - Senior ? Cltixen C - Ci ty • •DeFcrred , pe9. 8PECIAL, AHBESSMENT8 ?t? f0 ?PO '-' ?--- INPUT FORM - AUDITOR o1.1,ntcr 10 sA-cacrwEt 17I$ sx-rune 5s7'v?_?lqjR orsrnio-nzsr 10 eEr--YEn/7f 9_ ua-YEvM 15 ezRSi Y= nr T 0 99 i? zecvrsR ixr.28 5 0 oToznz nssessmerrr %sv v. o 0 Hark Activi[y ? NB1 ASSE531Et1f L--PAR66[,S DELINQUENr ANNUALS _ ASSF_SS.YFNt UPOA1E -? ADD/UPDATE PHRCELS Diviaion IST P[J1T LL71' BLK FA 1 lSSESSNEb7r JJ10lMP OEF CODE EFF YEAR FCT- ION lo Llo o ol 25.1 1?58 95co 00 . !988 ff ? '-- M;QiO ncriCU A - Jk3d ' C - Ctwnqe p '- 0.1ete P = Print boolcshee C O - 02d Parccl (divisfon) N - Ncu Parccl (divi9lon) DEF CODE S - Senior ' Citizcn C - ci ty • • [x:fcrred ucF•,oo a4sM - r+oaM a ruig. &w. o«wwro r-Joseph P. Earley Attorney at Law 7300 W. 147th St., Box 24329 Applil-Valley, MN 55124 L ' rThomas W. Bibus Attorney at Law Box 2038, Suite 103 6575 Cahill Ave. E. LInver Grove Heights, MN 55075 STATE OF MINNESOTA COUNTYOF Dakota NOTICE OF: El FILING OF ORDER El ENTRY OFJUDOMENT O DOCKEfING aF JUDGMENT Court Flle No.: C2-88-8935 _ IN RE: Ci[y of Eagan etc. vs Martin DesLauriers etal etc. 13 Ybu are hereby nodfied that on Mav 24th ? 1989 an Order was duly flled In the above entitled matter. O You aro hareby notlfled that on Mav 24th , 19 82_ a Judgment was duly entered in the above enGUed matter. ? You are hereby notlfled that on , 18 a Judgment was duly docketed In the above enGUed malter in the amount of _ A true and correct copy of thia Notioe hes been aerved by mall upon the paAles nemed herein at the Iast known address of each, purauant to Minnesota Rules ot Civll Procedure, Rule 77.04. Osted_ May 24th 1989 Ro¢er W. Sames • Court Adminlstrator py ???L¢-?? ??ra ?r?ehJ Deputy COURT ADMINISTRATOR DAKOTA COUNTY, MINN. ? F I L E D ? MAY 241989 ROGER W. SAMES, CLERK ""C"'09 x'r? ?EPUT7 5TA7'L OF MI.NNESOTA i;OUNT'Y UF 1I,1KqTA COURT ADMINISTRATOR DAKOTA COUNTY, MINN. F I L E D MAY 241989 N93ER W. SAMES, CLERf( -?DEPUTY Citp of Lagari, a municipal corporati.on. Fetitioner/ltespondent, vs. MarY.in llesLauriers and Marie UesL.auriers, husbflnd and wife, Appellants. IN DISTRICT COURT NINS'P JUDICLAL D1S'CH1CT Court Pile No. C2-88-8935 FINDINGS OE FACT CONCLUSIONS Or' LAW ORDSN FUR JUDGMENT AND ,7[IDGMENT 1'he above-entitled matter came on for trial before the unclersigned Judge of Uistrict Court on.the 4th day oP May, 1989, :it the Government Center, Hastings, Minnesota, regardittg an apPea] of the assessment of the DesLauriers Parcel 10-02600-0011- 52.. Jos?ph P. Earley, Esq „ appeared representing the Pet.itiouer/hc5pondent.. Thomas W. Bibus, Esq., appeared reprc:;ent.ing the ;1ppeLlahts. Now, t.herefore, based upon the file, records and proceedings horcin, ihe Court being duly advised in the premises makes the f<;! lotcing L?INDINCS OP FACT: (1) 7'hat the c;ity of Eagan shall be hereinafter referred to aa City 1nd the Appellants hereinafter referred to as UesLxuricrs. ('L) 7'hr;L Lhn itespondent herein is a municipal corporation 1 and, as such, has completed e storm sewer project for the Purpc>ses herein Lhzzt runs in front of the Appellants' home LocateQ on Clif.'L Road in Etagan, Minnesota. Said project is known sis the HoJ.laud Lal:e Trunk Sturm Sewer Project 444N. (3) Pliat the DesLauriers own a 6.3 acre tract on Cliff Itoacl; that a pnrtion uf that property hnd previously been subject to a condemnati.on, and the City has erected a lift station on naid propertp. SAid Li.ft station is used in connection with this sLorm sewer pro,ject. (4) Thtit the DesLauriers bought this property in 1977 and, shortly thereafLer, erected a home in the northeast portion of t.he property; that distances were not made available to the Court, but it is some distance Yrom the house to Cliff Road and serviced Ly ti gr.xxvel driveway; that the portion that is nearest. Cliff Itoad is lower arid, £rom time to time, would acc.umulate vriCer. The natural runoff of the surrounding terrain ran the w:iier in1:o that ].ow area. The water then passed through a r"].vert urider the DesLrxurier.s' driveway into the propertp i.mmediately cast, referred to rzs Carlson Pond. When Carlson Pond c•eached a cei•tain level, ttie water exited throttgh a culvert under ('].ifl' Road into Lalce Holland. 7'his flowage of water apparently hss eaisted foi snme period of time. (5) That rit the apparent urging of the County of Lakota to rlose off the storm water runoff into Lake Holland, the Citv ex•ecled this storm sc:cuer system. (Ei) Thai: the City has determined that the UesLauriers' 2 , prc,pertp has improved by $9,500.00 due to the construction of the storm sec:er, and hace so flssessed the propertv in that amount. f71 Thut the UesLauriers have objected; hence, this liLigation. (tf) That Lhe memorandum attached hereto shall be incorporated herein and made psrt of the Pindings. Now, tlierefore, based upon the foregoing, the Court makes t6e following (:ONCLUSION OF LAW: 'Chat the llesLauriers' property, Parcel 10-02600-0011-52, has not benefitec9 by the storm sewer installation; that, as such, this property should nut be ussessed for this pro,iect. LE.:T JUD(3MEN'P BE ENTERED ACCORlliNULY. Uatod: Me5• 23, 1989 MEMOHt1NllUPf The City in this matter finds i.tself with the usually difficult problem of endeavoring to prove thut the DesLauriers' property h<4;; impruved tlirough thc installAtion of an overall city improvemenl. A substant.i.al amount of acreaqe is serviced by the storm sewei and li.PL stution thAt was put on the DesLauriers' property as it lil'1.:; the water uiit of Carlson Pond. Said wlter previousl}• t;;n under Cliff Ruad and into Lake !{olland. The Court, being awnre of Lalte Fiulland, Pinds that it would take A 3 B]' TH1: C()UR'I': storm uf biblical proportions to overflow the banks of Lake Hulland and flnod ClifF Road. 1'he City daes have the burden of showing that the assessment oY' $9,950.00 improves the DesLauriers' property by an amount eqiial or qreater than that. The Court does not find that the Citc has met its burden. The Citp in its presenLati.on to the Court stated that the highest and best use of the propertg would be single family CIiJE'.lling, lt nota serves that purpose. The home owner had no Problem dealing with his runoff wnter Uefore this sewer was itist:alled b}• the Citp. It was not for his benefit that the sewer scst.em wns installed, Uut for the benefit of the commwiity at l;ir;e. The CnurC recn.lls the fi.gure of approximutely 2,700 acres immcdiatelc casL of the UesLauriers' property being served by thi:; sewei• sysLrm. Apparently, thete is little or no inctease in the amount serviced through the DesLauriers' property bc this sti•si,em. L;von though tkiis new aystem does not ylace uny greater bu+•deri on Lbe llesl,auriers' property, it is not more beneficial to his runoPf si.tunCion. if the highest and 6est use of the property, as set 1'orth by the City, is as it is now, single fnmily dwe]ling, t.hen it makes little sense for the City to talce the position that, it, is a substantial improvement to the DeSt,efurier property if they evcr wanted to develop the same. 'I'Le Court hAS di.fficulty in acceptinq the evaluations placed nu the propex•ty by the City. The Court noted that, before the alleged improvement, the propertv was served bv n bituminous 4 roadcaAy and electri.city; that, in the after situation, the pruperty was served by bituminous roadway, electricitp and trunk arca storm sewer. l.n every comparable, the comparative property was serced Ly- a].1 u1.il.ities, which are described as including ?as, el.ectricity, sunitary sewer, water, storm sewer and 6ituminotts TOSdW84-5. Therc has been rio objection to the process or the procedure im-olved hereiti. TLe matter simply comes down to a judgement call bp the Gourt based upon the evidence that was presented, the evaluation of the documentation, and the evaluation of the iaitnesses called before the Court in making its determination. As such then, the Caurt, finds thflt the Citv has not sustuined its burden 1s to showing, by a fair preponderance of the evidence, t}iat there has been nn}• improvement to the DesLaurier propertv. 'Che Coi.trt also notes the fact that it received, unsolicited, n ietter I'rom John J. Iilein, the home osaners' appraiser. Upon npu uing I.IiN envelope, the CaurC noted thet it contained a letter direct.ed to the Court, plus some ayparent exhibits. When the Court roal.irccl that it r.elated to this case, the material was placed bacl: in the envelope and not read or reviewed bq the uudersigned. Ptr. lilein ma,y be well meaning, but the Court takes grievous oFfense flt a witness who, apparently on his own voliti.on, attempts Co intervene and, es parte, influence the Conrt. 'Clic parties can be Assured that Ptr. 1{lein's extraneous ef'1'ort:: did noi: inf luence the Cottrt in making its determination onc wa}- ur the other. T.M.M. 5 I hereby certify that the Conclusion Of Law contained in this document shall constitute the JudgmenY of this Court. ?ate: May 24th 1989 ROGER W. SAMES Court Administrator Seal ?-( BY .? Y-?r_?i /J?.7i1?j Deputy Clerk / , ? ` HAUGE, EIDE & KELLER, P.A. J'lllorneys at al.aw TOWN CENTRE PROFESSIONAL $LDG.. SUITE 200 1260 YANKEE DOODLF ROAD EAGAN, MINNESOTA 55123-2201 (612) 456-9000 FAX: (612) 454-4232 July 21, 1989 Mr. Eugene VanOverbeke City of Eagan 3838 Pilot Knob Road Eagan, Mn 55121 Vr4- RE: City of Eagan v. DesLauriers Condemnation Action Dear Mr. VanOverbeke: PAULH HAUOE KEVIN W EIpE DAVID G KELLER DEBRA E SCHMID7 THOMAS P. LOWE Enclosed please find a check in the amount of $27,754.66 on check number 5699 from the Dakota County Court Administrator in regard to the above captioned action. I have also enclosed a copy of an Order and Judgment and a copy of the Cashier's Check closing out an account established by the Clerk of Court. If you will recall, the condemnation commissioner's originally awarded $60,000.00. We appealed on behalf of the City of Eagan and obtained a jury award of $16,000.00. The land owner was unsuccessful on a motion for a new trial. We were successful in a motion to require him to deposit $30,595.00 with the Court representing the difference between the jucy award and the $45,000.00 paid (inc2uding the origina2 quick take deposit) to the land owner pending appeal to the District Court pursuant to ^?innesota Statute. We tried to calcuiate the proper interest factors when arriving at that number. The land owner appealed the denial of a near trial and the City was again successful. Most recently the land awners attorney brought a motion for costs and disbursements totaling approximately $11,800.00. The Court may award costs and disbursements under Statute J117.195. We argued the case on July 11, 1989, and basically pointed out that most of the costs incurred by the land owner were due to the presentation of an improper claim for damage to two acres of potential ponding area. RECE(VEQ ,lul Z 4 9989 As you can see by the Order, the Court awarded the original $30,595.00 plus interest to the City of Eagan per our request except that $643.00 of interest which was due to the land owner was awarded , . Mr. Eugene Vanoverbeke July 21, 1989 Page 2 to the land owner. The Court then finally did award the land owner $3,000.00 of the $11,800.00 of costs and disbursements requested. Sincerely yours, HAUGE, EIDE, ANDERSON & KELLER, P.A. David G. Keller DGK:jh cc: Thomas Hedges Thomas Colbert James Sheldon i TRUST ACCOUNT ROGER SAME& COURT ADMINISiqqTOR DAKOTA COUNTV GOV'T. CENTEP HASTINGS, MN 55033 5699 15-110/919 PAV - `J?7 f 79 18..$9 70 THE CS'Y OY E ORDEROF J ?an $ ?nip 7?.66 Trrenty-Seven Thousand Seven Eundred FiYt -FOUr pol].e,rs An-d 66/100 j - - - - - - - . -DOLLARS e?:: NOrwesf Benk Hastmgs, N.A. N01111'lABnMKS Hestmgs,MN55033 XMIS Foq Fi1e #102628 & 104877 Iaeposzt release ursuan t ?`,p??Qrd??6?. 11'0056?9911¦ -_- ' C/ _ r?l. ?irn,d 09 02L Dil' .__-- mr•1oo (.+n hbra d fiq Rry, p"lmp rDavid G. Keller Attorney at Law Suite 200 Town Center Professional Building 1260 Yankee Doddle Raad ' LEagan, Mittnesota 55123-2201 STATE OF MINNESOTA COUNTY OF Dakota NOTICE OF: r O FILINa pF ORbER Thomas W. Bibus Attorney at Law X ENTRYOFJUDdMEIYT P. 0. Box 2038 ' 6575 Cahill Avenue East 0 DOCKETINO OFJUDC3MENT L-;nver Grove Heights, Minnesota 55075 CouR Ffle No.: C4-87-104877 IN RE; City of Eagan vs. Martln DesLauriers , et al C3 Yo+ am heiebY noUtled that on 19 an Otder was duly tiled In the above entitled meNer. You ero hereby noliflad that on July 14th ?g 89 a Judgment was duly enterod In the above enGUed maHar. r-3 1'ui ero hereby noUfled that on 19 a Judyment waa duly dxksted In the above enUUed mattsr in the amount o( s A trve and correct copyo( Ih?a Nottoe has been aerved bymall upon the partlss named hsrsin atlAs Inat known addresa of eaeh, purauent to Minnesota Rulea oi Clvil Procedure, RWa 77,04. D8ted- July 14th 1989 ROGER W. SAMES ' Court AdminlalraWr by IC • Depuly couRr i,Dn?liVisrr,atoR DAKera cou:vn•, R; INN. ? ! l [ E'1, ? JUL 141989 ROC+ER W. uAMES, CLEFiK J3EPUTY "W..,.. STATE OF MINNESOTA C`JUnT AU."Ocivi5TRATOR C,qKOTA GOU;,'T}', N:lNPJ. ? I L [ ?j JUl 14 1989 ? FIRST JUDICIAL DISTRICT COiTNTY OF DAKOTA DISTRICT COURT RE;GEii W. SAt:lES, 61ERk -------------- - ---------- . zj?urr------------------------- City of Eagan, Petitioner, V5. ORDER Martin DesLauriers and FILE NO. C4-87-104877 Marie DesLauriers, Respondent. AND JUDGMENT The above entitled matter came on for hearing before the undersigned, vne of the Judges of the above named Court, at the Dakota County Government Center, Hastings, on July 11, 1989. The Petitioner appeared through its attorney, David G. Keller, Esq. The Respondents appeared through their attorney, Thomas W. Bibus, Esq, The Court, having reviewed all of the files, records and proceedings herein, makes the following: ORDER 1. That the funds on deposit in file #102628 in the sum of $1,700.00, together with accrued interest, shall be paid to the Respondents. This sum represents condemnation proceeds deposited by the Petitioner on December 15, 1986. 2. The funds on deposit in file #104877 in the sum of $30,595.00, together with accrued interest, shall be disbursed as follows: a. The sum of $643.00 shall be paid to the Respondents, said sum representing interest due the Respondents. b. The sum of $3000.00 shall be paid to the Respondents, said sum representing costs and dis- bursements awarded to the Respondents. c. The balance of the funds in this account shall be, paid to the City of Eagan. 3. Except as Ordered herein, the Respondent's requests for an award of additional costs and disbursements is denied. LET JUDGMENT BE ENTERED ACCORDINGLY DATED: This 13th day of July, 1989. BY THE COURT WILLIAM F. THUET JUDGE JUDGMENT I hereby certify the above Order constitutes the Judgment ef the Court. Dated: July 14th 1989 ROGER W. SAMES COURT ADMINISTRATOR (Seal) $Y_;,' Depu[y Clerk T ?? Norwest 8ank Minnesota, N.A. C3SI?%@l's 5 3 4 6 5 2 0 monwisra4 Check LOLPAPFP@wkcopY1 US TO CLDSE ACCf, 23330:?'8 NI OO ? mu\JISLJI°1W(v cSL'TS CLEFK Of DIS'fRICT COUR? • DAKDTA COUHTY JULY 171 1989 *31,397.65 ? NoswesrBankMinnesora,N.A. G3Sh/Er'S AWR*VW enNKs Check 5346519 L00fT-"WW,aYYI US i0 CLOSE ACCT. 520655 JULY 17, 1989 MO? m'?'{'mT???}L?61CTS **11962.61 UV l?l u ??J CLERK OF AISTRICT CDURT BAKOTA COUMTY %??? CitV Of eCICJC111 3830 PILOT KNOB ROAD FAGAN, MINNESOTA 55122-1897 PHONE: (612) 454-8100 FAX: (612) 454-8363 MR. DAVID RELLER SAIIGE, EIDE, RELLERt P.A. ATTORNEY6 AT LAW TOWN CENTRE PROF. BLDCi., SIIITS 200 1260 YANREE DOODLE ROAD EAGAN, MN. 55123 RE: 10-02600-011-52 Project 444, Condemnation of Easemeats (DesLauriers) Dear Dave: VIC ELLISON Moyor 1HOPMS EGP.N DAV1D K GUSTAFSON PfNAEIA McCRFA THEODORE WP.CHfER C?II Members IHOMPS HEDGES Cily Admin'afralor EUGENE VAN OVERBEKE cny c?? I received a copy of your July 21st letter to Gene VanOverbeke closing out the condemnation action for the Martin DesLauriers property for the above-reference project. I just wanted to let you know that I was impressed with your representation of the City of Eagan in the handling of this matter in the best interests of the City of Eagan. Your efforts and expertise on behalf of the City of Eagan is emphasized by the favorable rulings of District Court in light of the numerous appeals by the property owner. Thanks for handling this matter through its favorable conclusion. Sincerely yours, 7 c -e-? -L.- Thomas A. Colbert, P.E. Director of Public Works cc: Thomas L. Hedges, City Administrator TAC/jf THE LONE OAK TREE...THE SYMBOL OF STRENGTH AND GROWfH IN OUR COMMUNIN Equal Opportunity/Affirmative Action Employer /. r!. Page 20/CITY COUNCIL MEETING MINUTES October 6, 1988 McCrea moved, Egan seconded, the motion to close the public hearing and reaffirm the original final assessment roll for Pro7ect 476 (Wescott Road) as it pertains to Parcel 10-01400-030-53 and authorize its certification to the County. All voted in favor. PRQ7ECT 444R, HOLLAND LllRS STORM SE1?iSR {(PIIRCBL 10-02600=011=52T, Public works Director Tom Colbert stated that the improvement that was installed handles the storm water runoff fran the subject property through the City's trunk storm sewer system all the way to the Minnesota River. He further stated proper credits were applieb foc potential future cight-of-way and easement dedications if and when the property should ever fievelop, ee stated it is properly assessed in accordance with City policies and procedures and the current zoning and use of the property. However, due to the fact that the City's appraisal report indicated that the increased market value is less than the proposed assessments, it was staff's recommendation that the proposed final assessment be reduced to $9,500.00. Martin DesLauriers objected to any assessment as he stated there was no benefit to his property. He stated his property had lost value. He distributed a han6out to the Council and showed the location. He stated he felt the property would be flooded and f urther explained reasons for his objection. He requested deferment until the holding pond was defined. Mr. Colbert stated the storm sewer plan locates 340 drainage areas. He further stated the City was not in need of it now, but that upon saturation it may be needed. He stated the plan would be revised in the future but he did not know what the future would bring. He outlined the benefit to DesLauriers' property. Councilmember Egan questioned how the assessment would be abated. l1r. Colbert stated by agreement. He stated the real issue was how much of the area should be included ana that at the present time, he was uncertain of that amount. He stated he would need to see the develognent proposal ana he would prefer to postpone, not abate. Mr. DesLauriers stated it was not acceptable to him to just postpone the matter. Much discussion was held regarding the ponding. Councilmember Egan questioned that if the City would abate, if there would be a need for a ponding area. City Attorney Jim Sheldon stated there were two issues: 1. Benefit to the land nowf and 2. Acquiring the ponding easement. Page 21/CITY COUNCIL MEETING MINUTES y October 6, 1988 He stated the City should deal with the second issue at the time of the development, ee further stated the appraisal amount was separate from the issue of the future developaent. Mr. DesLauriers reiterated his concerns. There was much discussion regarding the ponding and the assessments. Egan moved, Gustafson seconded, the motion to close the public hearing and approve the final assessment roll for Project 444R (8olland Lake Storm Sewer) as ft pertains to Parcel 10-02600-011-52, as recommended by the Special Assessment Committee, ana authorized its certification to the County. Wachter, Gustafson, Ellison and Egan votea in favor; McCrea votea against. PROJECT 460A, NIC80LS ROAD, PARCBL 10-03000-010-29 Public Works Director Tom Colbert informed the Council the affected property was properly assessed in accordance with its zoning classification, and opportunities to reduce the assessment in accordance with its present use were extended to the property owner. Therefore, it was the staff's recommendation that the original assessment be reaffirmed based on its zoning classification or that the reduced assessment be certified subject to the timely execution of the required agreements. Mr. Adelman stated that he agreed to the $4,500.00 amount but would not sign the agreement. He stated he would like the matter settled. He informed the Council that he had lived on the prope rty for 29 years. Councilmember Egan informed Mr. Adelman that unless he took the step to re-zone, nothing would happen and that he had complete control of the matter. Mr. Egan explained the effect of the agreement. He stated it was a non-issue. Mayor Ellison stated he felt it was fair to tax commercial higher than residential. Mr. Colbert stated the agreement allows a way to find the exact amount if the use was changed. McCrea moved, Egan seconded, the motion to close the public hearing and reaffirm the final assessment roll for Project 460A (Nichols Road) as it pertafns to Parcel 10-03000-010-29 and authorize its certification to the County. All voted in favor. PROJBCT 460A, NICHOLS ROADo LOT 1t BLOCH 2# CBDJlR RIDGB 1ST ADDITION Public Works Director Tom Colbert informed the Council the assessments were properly calculated and allocated in accordance with adopted policies and procedures #or all similar zoned-type property. Based on the appraisal by the City verifying an increase in market value at least equal to the amount of the proposed assessments, it was the staff's recommendation that the original assessment as proposed be reaffirmed. oF 3830 PILOT KfVOB ROAD, P.O BOX 21199 VC fLLV50w EAGAN, MINNESOiA 55121 M?r PHONE(612) 454-8700 TMpMws EGqiv DAV1D K GUSTAFSON PAMEIA McCR64 February 9, 1988 nieoooaEwncHTEa CouncllMembers Martin & Marie Des Lauriers n+onnasHEOeEs 5459 Hermosa Vista C?rynOministmtw AN OVERBEKE EUGENF N 1e Mesa, AZ 85205 RE: SPECIAL ASSESSMENT OBSECTION - PROPERTY APPRAISAL/VIEWING PARCSL NO. 10=02600=011-52 7 Dear Mr. and Mrs. Des Lauriers: On September 21, 1987, a letter was sent to your attention informing you that your written objection to the proposed final assessments for the above-referenced project was being forwarded to the Special Assessment Committee scheduled to meet in April of 1988. That letter also informed you that the City would be performing a formal appraisal of the property to verify that the benefit to your property through increased value was at least equal to the amount of the proposed assessments. This letter is to inform you that Mr. Dan Dwyer of the appraisal firm of Dahlen & Dwyer will be contacting you in the near future to review your property in detail. This will require access to your house to help determine the valuations associated with your property. While I recognize that this may be an inconvenience, it would be greatly appreciated if you could extend every courtesy to Mr. Dwyer in performing this property appraisal so that the zeport can be completed in a timely manner to be forwarded to the Special Assessment Committee. Mr. Dwyer will be contacting you in advance to schedule a time convenient for both parties. Your continued patience and cooperation through this process is greatly appreciated. Sincerely, ? Thomas A. Colbert, P.E. Director of Public Works ec: Paul Hauge, City Attorney Dan Rwyer, City Appraiser TAC/jf THE LONE OAK TREE. ..THE SYMBOL OF STRENGTH AND GROWTH IN OUR COMMUNIiY itv oF 3830 PILOT KN08 ROAD. P.O. BOX 21199 _ BEA BLOMQUIST EAGAN. MINNESOTA 55127 Mwor PHONE' (612) 454-8100 TMOM,yq EC-AN JAMES A SMIIFi VIC ELLISON September 21, 1987 oa?m? a n+?o o nionnas HeoeEs Ciry Admmistrafar MARTIN & MARIE DESLAURIES EUGENEVANpVERBEKE 1031 CLIFF ROAD Ciry clerk EAGAN MN 55122 55123 Re: Project #444R, Parcel #10-02600-011-52 ? Special Assessment Objection Dear Mr. & Mrs. DesLauries: At the formal public hearing before the City Council, you submitted a written objection to the proposed final assessments against your property for the improvements associated with that project. Subsequently, the Council deleted your property from the final assessment roll that was formally adopted and certified to the County for certification onto the tax rolls. Your objection was then referred to the Special Assessment Committee for an in-depth review of the improvements, the related benefit to your property and the proposed assessments. This Special Assessment Committee is comprised of two Council members, two Planning Commission members and three residents of the community. After their review, they will forward a recommendation to the City Council for formal consideration of final adoption of the proposed assessments. The Council's consideration of the Special Assessment Committee's recommendations will be held at a future formal public hearing and mailed notification similar to the public hearing process you recently completed. While there is no definitive schedule for the Special Assessment Committee meetings, it is riot anticipated that this item will come before that Committee any sooner than April of next year. In the interim, the City will be performing a formal appraisal of your property to verify that the benefit to your property through increased value was at least equal to the amount of the proposed assessments. This appraisal process will be coordinated through our City Attorney's office during the ensuing months. When the Special Assessment Committee meeting has been scheduled, you will be so notified in writing with a request to provide any iHE LONE OAK TREE. ..iHE SYMBOL Of STRENGiH AND GROWfH IN OUR COMMUNITY September 21, 1987 Page 2 additional information or appraisals you may have compiled in the interim. Once all this information has been gathered , a staff report will be prepared for the Committee meeting with a copy forwarded to your attention prior to that meeting. In the interim, this special assessment will continue to be listed as a"pending" assessment but there will be no interest accrued beyond the amounts proposed at the time of the recent final assessment hearing. If you have any other questions regarding this procedure or your assessment, please feel free to contact me at your convenience. Si rely, ? ?? (.? '. ?? ' Thomas A. Colberr-P .E. Director of Public Works TAC/jj cc: Paul Hauge, City Attorney Deanna Kivi, Special Assessment C1eYk IV. NEW BUSINESS C. PROJECT 444R, HOLLAND LAKE TRUNK STORM SEWER 1. Martin Des Lauriers (Parael 10-02600-0011-52) BACKGROUND INFORMATION This project provided for the installation of a complex trunk storm sewer system generally located along Cliff Road by EIOlland Lake. It provided for the installation of a storm sewer lift station on Mr. Des Lauriers property providing a controlled outlet structure for the pond located adjacent to and east of this property. This project was approved on June 17, 1986, with construction being completed by July of 1987 and the final assessment hearing held on September 1, 1987. Enclosed on page q I_ is the written property owner regarding these propose pages ?? through ?? is some recen the property owner further supporting original objection. Enclosed on page maps showing the relationship of the improvements as well as the calculatio fin assessment amounts. Also encl are excerpts of the forsal appr t is property identifying the inc resulting from this improvement. STAEE RECOMMENDATIONS objection submitted by the d assessments. Enclosed on t information submitted by his osition regarding his s through C? are property to the proposed ns used to arrive at the osed on pages ?e through aisal report performed on reased value of property The improvement installed handles the storm water runoft from the subject property throuqh the City's trunk storm sewer system all the way to the Minnesota River. Proper credits were applied for potential future right-of-way and easement dedications if and when the property should ever develop. It is properly assessed in accordance with City policies and procedures and the current zoning and use of the property. However, due to the fact that the City's appraisal report indicates that the increased market value is less than the proposed assessments, it is staff's recommendation that the proposed final assessment be reduced to $9,500. COMMITTEE RECOMMENDATIONS/COMMENTS t *9, s ° ° PtA' yd r -1`` ?? Q? June 21,1988 To: Special Assessment Committee Reference: Assessment of Martin and Marie Des Lauriers property at 1031 Cliff Rd PID # 10-02600-011-52. Containing approx. 6 and one half acres and single family home. We received a notice in the mail on June 16th,1988 of this hearing to be held on June 30th,198II (only fourteen days notice). We have made arrangements some time ago to be out of the area on June 30th. We are objecting to the assessment on our property on the basis that project #444R did not benifit our property, and in fact it has caused a damage to the property. Rather that removing storm water, this project raised the water level, causing flooding that normally or naturally flowed into Holland Lake. Our property drained naturally from a low elevation of 872 feet into the Carlson property to the east of ours, then from Carlson's through a culvert into Holland Lake at an elevation of 867 feet. The culvert under Ciiff Rd to Holland Lake has been closed. Project #445 states a high water level of 880 feet elevation on our property. (See attachments 1,2 and 3) We had a concern in 1979 when the city allowed Ches-Mar East to develop and drain storm water into Dr Frank Nuttalls' property, which is west of our property. Then from Dr Nuttalls', water flowed onto our property. At that time we were assured incorrectly by Robert Rosene and Tom Colbert not to be concerned beCause all the water would continue into a storm sewer from our property at time of development. Now with project #444R our property is to be part of holding ponds at high water levels! (see attachment4). It is our understanding for a governmental body to assess a parcel of property, the property assessed must be benifited. Our property is not benifited! We are disappointed not to be able to attend this hearing on June 30th at such a short notice. Si ely v ` M tin Des Lauriers " 014ke,? &, Marie Des Lauriers /J C?