HomeMy WebLinkAbout8A, Settlement Payment to James & Julie Rechtiene for Damage to Driveway
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_HILLS
Request for Council Action
Prepared By:
Greg Hoag
Council Meeting Date: August 10, 2009
Approve the full and final settlement between the eity of Arden Hills and James and Julie
Rechtiene in the amount of $1750 for damages caused to the driveway at 3327 Dunlap Street.
Budgeted Amount:
$0
Actual Amount:
$1,750.00
Funding Source:
Water Utility
Recommendation:
1. Approve the full and final settlement agreement between the City of Arden Hills
and James and July Rechtiene in the amount of $1750 for damages caused to the
driveway at 3327 Dunlap Street.
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Supportin!! Documents:
1. Memorandum dated August 10,2009 from Public Works Director
2. August 11,2008 City Council Staff Memo and meeting minutes (Attachment A)
3. August 18, 2008 Work Session minutes (Attachment B)
4. August 4, 2009 Letter from City Attorney Jerry Pilla (Attachment C)
5. Revised Settlement and Release Agreement (Attachment D)
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MEMORANDUM
DATE:
August 10, 2009
TO:
Honorable Mayor and City Council
Ron Moorse,City Administrator
FROM:
Greg Hoag, Public Works Director
SUBJECT:
Driveway Settlement 3327 Dunlap Street
BACKGROUND
On November 7, 2007 the Public Works Department repaired a broken water main under the
driveway in the city right of way at 3327 Dunlap Street. The property owners notified us that
they had just replaced the driveway in the late summer and the contractor had provided the
residents with a two year warranty. Due to our digging up and patching a portion of the new
driveway to complete the repair of the water main, the driveway contractor informed the
residents that the warranty on the driveway was now void.
This item was first introduced to the City Council at the regular meeting on August 11, 2008. At
that time Council passed a motion to table the item to the next Work Session for further
discussion. (Attachment A, staff memo and minutes)
The item was discussed at the August 18,2008 Work Session. After discussion it was the
consensus of the City Council to direct staff to offer to replace the driveway within the right-of-
way or to refer the driveway request to the League of Minnesota Cities. (Attachment B, minutes)
After that meeting staff contacted the resident to discuss the City Council offered direction. The
residents stated that they would like to continue to explore their options and to not turn the issue
over to the League of Minnesota Cities or to complete any repairs. They stated the ball was in
their court for the next actions.
In December of2008, City Attorney, Jerry Filla spoke with an Attorney representing the
residents. At that time they spoke as to some additional options for resolving this issue. These
discussions have been back and forth between City Attorney Filla, the resident, and their
Attorney. The current proposal from the residents is for the City to pay the residents $1,750 as a
full and final settlement. (Attachment C, memo to Greg Hoag from City Attorney Filla) City
Attorney Filla is recommending the City accept the revised Settlement and Release Agreement
from the residents. (Attachment D)
Page 2
ST AFF RECOMMENDATION
Approve the full and final settlement between the City of Arden Hills and James and Julie
Rechtiene in the amount of$I,750 for damages caused to the driveway at 3327 Dunlap Street.
RECOMMENDED COUNCIL ACTION
Approve the full and final settlement between the City of Arden Hills and James and Julie
Rechtiene in the amount of$I,750 for damages caused to the driveway at 3327 Dunlap Street,
and authorize the Mayor and City Administrator to execute the revised agreement.
Attachment A
Staff Memo and Meeting Minutes
from August 11, 2008
August 10, 2009, City Council Meeting
rf\
MEMORANDUM
DATE:
August 11, 2008
TO:
Honorable Mayor and City Council
Ron Moorse, City Administrator
FROM:
Greg Haag, Public Works Director
SUBJECT:
Driveway Repair 3327 Dunlap Street
BACKGROUND
On November 7, 2007 the Public Works Department repaired a broken water main under the
driveway in the city right of way at 3327 Dunlap Street. The property owners notified us that
they had just replaced the driveway in the late summer and the contractor had provided the
residents with a two year warranty. Due to our digging up and patching a portion of the new
driveway to complete the repair of the water main, the driveway contractor informed the
residents that the warranty on the driveway was now void.
Over the last few months City staff and the City Attorney have been working with the residents
on a settlement agreement for the damage caused to the driveway. Attached is the Settlement
and Release Agreement for your review.
STAFF RECOMMENDATION
Approve the Settlement and Release Agreement between the City of Arden Hills and James and
Julie Rechtiene in the amount of$4,140.00 for damages caused to the driveway at 3327 Dunlap
Street.
RECOMMENDED COUNCIL ACTION
Approve the Settlement and Release Agreement between the City of Arden Hills and James and
Julie Rechtiene in the amount of$4,140.00 for damages caused to the driveway at 3327 Dunlap
Street, and authorize the Mayor and City Administrator to execute the agreement.
ARDEN HILLS CITY COUNCIL - August 11, 2008
6
Assistant City Administrator Simon stated that he did not anticipate that a person
would be assisting for a long periods of time. He also stated that several of the
Assistant Deputy Clerks will be filing in at the front counter.
Assistant City Administrator Simon confirmed that Dorothy McClung was not
being compensated for her services this year per her request.
Councilmember Grant asked Assistant City Administrator Simon why his name
was not on the list.
Assistant City Administrator Simon stated that earlier in the year the Council had
appointed him by resolution as the Deputy Clerk.
MOTION: Councilmember McClung moved and Mayor Harpstead seconded a
motion to Approve Resolution 2008-038: A Resolution Appointing
Election Judges for the 2008 Primary and General Election. The
motion carried unanimously (4-0).
B. 3327 Dunlap Street Drivewav Settlement and Release A2reement
Councilmember Grant stated that this item had not been brought to the Council
previously and the item requires more discussion by the members of the Council.
MOTION: Councilmember Grant moved and Councilmember Holden
seconded a motion to table item 5B for further discuss at the next
available work session.
Mayor Harpstead asked City Attorney Filla if there were any time senSItIve _
materials that needed to be decided immediately or if the item could be tabled until
a later date.
City Attorney Jerry Filla stated that there were no time sensitive materials that
needed to be decided and that tabling the item would be acceptable.
The motion was called to a vote. The motion carried unanimously (4-0).
6. PUBLIC HEARINGS
None.
7. NEW BUSINESS
Attachment B
Meeting Minutes from August 18, 2008
August 10, 2009, City Council Meeting
B. Discussion Regarding the Release and Settlement Agreement for the
3327 Dunlap Street Driveway
Public Works Director Hoag presented the City Council with information
regarding the property at 3327 Dunlap Street. He explained that last November a
watermain broke underneath this property, which had a brand new driveway,
complete with two year warranty. The resident was not happy with the replacement
patch and asked that the driveway be replaced.
Public Works Director Hoag indicated the resident were not satisfied with the
suggestion of a saw cut replacement or patch job on the driveway. He noted he
spoke with the City attorney on this issue. After much discussion, he is asking that
the driveway be completely replaced to appease the resident and to provide her
with a warranty.
Councilmember Holden asked which account the $4,100 was budgeted from.
Public Words Director Hoag noted the funds were budgeted from the Watermain
Repair Parts Account and that this amount covered the replacement of the entire
driveway.
Discussion ensued regarding the replacement of this driveway and how these
incidents have been handled in the past.
Councilmember Holmes stated she didn't understand why this resident should
receive a whole new driveway when other residents have received a patch job.
Mayor Harpstead suggested the tail end of the driveway be fixed and made
uniform with the City providing a one year warranty on the entire driveway.
Councilmember Holmes asked how much it would cost the City to replace the
bare minimum, the area within the right-of-way with a saw cat patch.
Public Works Director Hoag estimated this expense to be $500-700.
Mayor Harpstead indicated that while this is a much lower cost, the expense of
defending a lawsuit would be far greater if the resident were not satisfied with the
City's response.
Councilmember Holden noted she was in favor of the $4,000 expense to replace
the driveway.
Councilmember Grant stated he was not in favor of paying the resident the
$4,000 to have the driveway replaced but that a contract would have to be arranged
between the City and her contractor.
Mayor Harpstead agreed.
Mayor Harpstead asked staff how the Council should proceed.
Public Works Director Hoag indicated he feels staff has provided this resident
with the best possible services to date and that Council should proceed with caution
with this resident.
Mayor Harpstead thanked staff for working so patiently with this individual. He
questioned if a precedent would be set within the City if Council agreed to pay for
the entire driveway. Due to this fact, he suggested again, that the bottom of the
driveway be replaced to the best of the City's ability and that a one year warranty
be offered on the entire surface.
Councilmember Grant suggested the asphalt be repaired where disturbed and that
the Council not commit to replacing the entire driveway.
Councilmember Holden asked if the repaired bottom could be one entire piece.
Public Works Director Hoag indicated the City would replace this as one piece,
but that the resident will not be happy with the City employees completing this
work and will want her contractor and his bituminous.
Mayor Harpstead stated he would be in favor of the resident's contractor
completing the repair to avoid future concerns.
Councilmember Holmes indicated she was not in favor of this special request
because it would set a precedent for future driveway concerns.
Councilmember Grant suggested the contractor be contacted to see where his
bituminous comes from to allow the City to use the same product to provide
uniformity on her driveway.
Public Works Director Hoag stated that all disputes in the future will be directed
to the insurance company to avoid this type of problem. He suggested this item be
sent to the League of Minnesota Cities for resolution.
Councilmember Holmes stated she was in favor of treating this request just like
every other resident within the City, who doesn't request a full driveway
replacement.
Mayor Harpstead indicated he was in favor with sending this issue to the League
of Minnesota cities as well.
It was the consensus of the City Council to direct staff to offer to replace the
driveway within the right-of-way or to refer the driveway request to the League of
Minnesota Cities.
Attachment C
August 4,2009 Letter form City Attorney,
Jerry Filla
August 10, 2009, City Council Meeting
Warren E. Peterson
Jerome P. Fil1a
Daniel Witt Fram
Glenn A. Bergman
John Michael Miller
Michael T. Oberle
Steven H. Bruns.
Paul W. Fahning.
Sonia R. Ortiz
Amy K. L Schmidt
Ben I. Rust
Jonathan R. Cuskey
Jared M. Goerlitz
P~ERSQ\JI
FRAM - BERGMAN
Suite 800
55 East Fifth Street
St. Paul, MN 55101-) 7 J 8
(651) 291-8955
(651) 228-1753 facsimile
www.pfb-pa.com
PROFESSIONAL ASSOCIATiON
(651}290-6907
ifilla((i)pfb-oa.com
August 4, 2009
Greg Haag
Public Works Director
City of Arden Hills
1245 West Highway 96
Arden Hills, MN 55112
VIA EMAIL
Re: 3327 Dunlap Street
Proposed Driveway Settlement
Our File No.: 10450.08-15
Greg:
This correspondence will summarize my conversations and correspondence with Mr.
Rechtiene and his attorney:
1. Prior to June 25, 2009J Mr. Rechtiene offered the City two (2) settlement
options:
a. He would provide a full release of claims in return for $2,000.
b. He would provide a full release of claims for $1,700 if a City crew
removed the damage area. Essentially, he thought he could save
$300 by having the City crew do part of the work.
2. On June 25, 2009,1 stated that we would recommend one of the following
counteroffers:
a. A full release for $1,200.
b. A full release for $900 and the City crew would remove the damaged
area.
3. On July 16J 2009, Mr. Rechtiene's attorney said that his client would
accept $2,000 for full release of claims.
4. I called Mr. Rechtiene's attorney and, after some discussion, he stated that
his client would accept $1,750 for full release of claims.
. ALSO ADMITTED IN WISCONSIN
Greg Haag
August 4, 2009
Page 2
I think that we have gone as far as we can. If this matter is litigated, it will cost
the City more than $1,750 whether the case is handled by our office or by the
league of Minnesota Cities Insurance Trust. I think $1,750 is the least costly
solution and this is what I am recommending.
JPF/jmt
cc: Ron Moorse
F:\users\JessicaVerry\Arden HiJls\Correspondence\Hoag Ltr-5.5. 09.doc
Attachment D
Revised Settlement and Release
Agreement
August 10, 2009, City Council Meeting
SETTLEMENT AND RELEASE AGREEMENT
1.0 Parties. This Settlement and Release Agreement ( "Agreementll ) IS
entered into by and between the City of Arden Hills, a Minnesota statutory city
( "(ityll); and James Rechtiene and Julie Rechtiene (collectively herein
"Rechtienes" ).
2.0 Recitals.
A. Rechtienes are the owners of the following described real property
( I'Property" ) situated in Arden Hills, Minnesota:
Lot I, Block 8, Josephine Hills, Plat No.2
B. In 2007, the Rechtienes hired a contractor to install a new driveway
to serve the Property ( "Rechtiene Driveway" ).
c. Shortly after the Rechtiene Driveway was installed, the City had to
repair a City watermain segment.
D. The City watermain segment was located within the unimproved
portion of the right-of-way adjacent to the Property and below the
Rechtiene Driveway.
E. A portion of the Rechtiene Driveway was saw cut, removed and
patched by the City after the watermain segment was repaired
( "Project" ).
F. The Rechtienes contractor would not warrant the Rechtiene
Driveway because the City had removed and patched a section of
the Rechtiene Driveway and, in order to obtain the warranty, the
Rechtiene Driveway would need to be reinstalled from the improved
portion of the City street to the garage.
G. The Parties have agreed to resolve this matter pursuant to the terms
of this Settlement and Release Agreement.
3.0 Terms and Settlement. NOW THEREFORE, in consideration of the mutual
undertakings herein expressed, the Parties agree as follows:
A. Upon execution of this Agreement by the Parties, the City shall pay
Rechtienes the sum of $1,750 ( "Settlement Amount" ).
B. In consideration of the payment of the Settlement Amount,
Rechtienes for themselves and their successors and assigns agree to
release the City, its employees and contractors from any liability or
claims whatsoever, known or unknown, arising out of, or in any way
related to the Project.
c. This is a Settlement Agreement and not an admission of liability.
D. This is a legally binding document and each party has had an
opportunity to consult with legal counsel.
E. This Agreement may be executed in counterparts by the parties.
IN WITNESS THEREOF, the parties have executed this Settlement and
Release Agreement on the dates set forth below.
CITY OF ARDEN HILLS
Dated:
By:
Stan Harpstead
Its: Mayor
2
Dated:
By:
Ronald Moorse
Its: City Administrator
STATE OF MINNESOTA )
) S5.
COUNTY OF
On this _ day of I 2009[ before met a notary public
within and for said county, personally appeared Stan Harpstead, the Mayor of
the City of Arden Hills, and Ronald Moorse, the City Administrator of the City of
Arden Hills, and they executed the above Settlement and Release Agreement as
their own free act and deed.
Notary Public
3
Dated:
James Rechtiene
Dated:
Julie Rechtiene
STATE OF MINNESOTA
) SSe
)
COUNTY OF
On this _ day of , 2009, before me, a notary public
within and for said county, personally appeared James Rechtiene and Julie
Rechtienel husband and wifel and they executed the above Settlement and
Release Agreement as their own free act and will.
Notary Public
4