HomeMy WebLinkAbout11-332JULY 26, 2011 11 -332 RESOLUTION
(CARRIED 6 -0 LOST LAID OVER WITHDRAWN )
PURPOSE: APPROVE AGREEMENT FOR RIGHT -OF -WAY ACQUISITION /
JACKSON STREET — MURDOCK AVENUE INTERSECTION
IMPROVEMENT PROJECT
INITIATED BY: PUBLIC WORKS DEPARTMENT
WHEREAS, by Resolution 08 -469 adopted on December 9, 2008, the Common
Council approved a revised relocation order and approved a Determination of Necessity
pursuant to Sec. 32.07 of the Wisconsin Statutes, to acquire certain land for right -of -way
purposes at the Jackson Street and Murdock Avenue intersection; and
WHEREAS, by Resolution 09 -286 adopted on July 28, 2009, the Common Council
approved a jurisdictional offer of $26,100.00 to acquire property located at 502 W.
Murdock Avenue owned by Laser Investments and including the interest of First National
Bank -- Fox Vally; and
WHEREAS, the City of Oshkosh acquired title to the property by filing with the
Winnebago County Circuit Court an Award of Damages; and
WHEREAS, by subsequent landowner appeal, the circuit court ordered the parties
to mediation over the disagreement as to the appropriate amount of compensation for this
acquisition and the parties reached a tentative agreement, subject to final Council
approval, providing that the City of Oshkosh would pay an additional $6,000.00 over and
above the City's Award of Damages by sending payment to the Clerk of Circuit Court for
Winnebago County to be disbursed for the benefit of the property owners.
NOW, THEREFORE, BE IT RESOLVED by the Common Council for the City of
Oshkosh that the tentative agreement is hereby approved and the proper City officials are
hereby authorized and directed to sign all documents and to undertake those steps
necessary for implementing this agreement.
BE IT FURTHER RESOLVED that money for this purpose is appropriated from:
Acct. No. 315 - 0410 - 7208 -00000 Street Improvement Fund Expenditures —
Jackson Street Roundabout
CITY HALL
215 Church Avenue
P.O. Box 1130
Oshkosh, Wisconsin
54903 -1130 City of Oshkosh
OfHKO rH
TO: Honorable Mayor and Members of the Common Council
FROM: Lynn A. Lorenson, City Attorney
DATE: July 21, 2011
RE: Approval of Settlement Agreement with Laser Investments, LLC and First
National Bank — Fox Valley / Appeal from an Award of Damages in
Eminent Domain for Property located at Jackson Street — Murdock
Avenue Intersection Improvement Project
BACKGROUND
As part of the City's Agreement with the Wisconsin Department of Transportation, the
City of Oshkosh was responsible for acquiring certain property for the Jackson
Street/Murdock Avenue intersection improvement project including a portion of the
property located at 502 W. Murdock Avenue owned by Laser Investments, LLC. In
addition to the interest of Laser Investments LLC, the property records showed an
interest on behalf of First National Bank — Fox Valley. By Resolution 08 -469 adopted on
December 9, 2008, the Council determined the necessity for acquisition of the property
and adopted the required relocation order. The City and the property owner were
unable to reach an agreement as to the acquisition price for the portion of land required
for the project and the City, by Resolution 09 -286 adopted on July 28, 2009, directed
the issuance of a jurisdictional offer in the amount of $26,100.00 to acquire the property.
The property owner appealed from this award to the Circuit Court for Winnebago
County. In the Appeal, the City was represented by Attorney Ben Southwick whose
practice focuses on eminent domain litigation. The parties to the lawsuit participated in
mediation with Attorney Timothy A. Hawley acting as the agreed upon mediator. A
proposed settlement was reached in mediation, but is contingent upon approval by the
Common Council. The proposed settlement would require the City to pay an additional
$6000.00 over and above the Award of Damages payment, making the total
compensation for the property $32,100.00.
The subject property is commercial property located along Murdock Avenue to the west
of the intersection with Jackson Street. The area taken was approximately 574 square
4.:
feet for right of way purposes. In addition, a temporary easement of 1612 square feet
for construction purposes was also taken.
ANALYSIS
The City paid $26,100.00 for the property taken at 502 W. Murdock Avenue for the
interchange project. Statutes allow the owners of property to appeal an award of
damages when property is taken. The property owners in this case requested
compensation in the amount of $40,000.00. The proposed settlement requires the City
to pay an additional $6,000.00 to the property owners making the total amount of
compensation paid for the property $32,100.00. In exchange the City would receive a
full release of all claims relating to the property acquisition.
With regard to the risks of not approving the proposed settlement, if the City would
proceed to litigation the City would incur additional attorney fees, costs for experts and
other costs associated with a trial. In addition, should a jury award the property owner
an amount more than 15% greater than the original award of damages, in this case any
amount in excess of $3915.00 in additional compensation, by statute the City would be
liable for all of the property owner's litigation expenses, including its attorney fees.
Should a jury uphold the Award of Damages, the City would incur no additional costs for
compensation but would incur the additional legal fees and costs of litigation. If a jury
awarded less than the original Award amount, the property owner may have to repay
amounts previously paid.
FISCAL IMPACT
The proposed settlement would result in an additional payment to the property owners
of $6,000.00.
RECOMMENDATION
If there are questions or concerns related to the City's proposed legal strategy or
positions in this matter, I recommend that they be discussed in a closed session
pursuant to section 19.85(8) of the Wisconsin Statutes which would allow the Council to
meet with legal counsel concerning strategy to be adopted by the body with respect to
litigation in which it is or is likely to become involved. Questions regarding the basic
facts or history of the project or other non - sensitive matters can, of course, be
discussed in open session. Therefore, if any member of the Council has questions or
concerns regarding the proposed settlement please contact the City Attorney's office to
discuss the matter and /or to request that this matter be placed on the Council's Agenda
for a closed session to allow for additional discussion. If a closed session is not
requested, this matter will remain on the Council Agenda as a resolution to approve the
attached settlement.
Based upon all of the facts of this case and consideration of the law governing the
eminent domain process, Staff recommends that the Council approve the settlement
agreement.
Res ectfully Submitted, Approved:
Lyn A. Lorenson Mark A. Rohloff
City Attorney City Manager