NJ Supreme Court Rules On West Orange Library Dispute

WEST ORANGE, NJ — The New Jersey Supreme Court ruled on a case involving the West Orange Public Library on Monday, finding that its recent designation as an area in need of redevelopment is “invalid.”

Here’s a summary of the case, according to Justia.com:

“At issue in this case before the New Jersey Supreme Court was whether the Township of West Orange improperly designated the site of its public library as an area in need of redevelopment under the Local Redevelopment and Housing Law (LRHL), N.J.S.A. 40A:12A-1 to -49. The local Planning Board hired a consulting firm to evaluate the library. The firm concluded the library met the statutory conditions. The board, in turn, adopted that conclusion and recommended the site of the library be designated an area in need of redevelopment. The Township Council agreed. Plaintiff Kevin Malanga, who lived in West Orange, filed a lawsuit to challenge the designation. The trial court rejected his arguments and dismissed the complaint, and the Appellate Division affirmed. The Supreme Court found the township’s designation was not supported by substantial evidence in the record: the record did not establish that it suffered from obsolescence, faulty arrangement, or obsolete layout in a way that harmed the welfare of the community. The township argued that even though the library actively provided services to the residents of West Orange, it could have better served the public if it had more programming and computers, among other things. ‘That laudable concept, by itself, does not satisfy the standards in the LRHL.’”

The NJ Supreme Court also provides a summary on its website:

“Like many older buildings, the library needed improvements in a number of areas. But the record did not establish that it suffered from obsolescence, faulty arrangement, or obsolete layout in a way that harmed the welfare of the community. To designate property for redevelopment under the LRHL, a municipality must demonstrate that certain specified problems exist and that they cause actual detriment or harm. There is insufficient evidence in the record to meet that standard. The designation of the library as an area in need of redevelopment is invalid.”

“Like many older buildings, the library needed improvements in a number of areas,” the court ruled in its written opinion. “But the record did not establish that it suffered from obsolescence, faulty arrangement, or obsolete layout in a way that harmed the welfare of the community.”

“The designation of the library as an area in need of redevelopment is invalid,” the judges said.

The judges added that towns like West Orange that are faced with similar situations have several options.

“Among others, they can make needed improvements to public property,” the court wrote. “They can invite bids for construction projects subject to particular specifications. And they can designate areas in need of redevelopment provided they satisfy the specific standards in the LRHL.”

“The township represented at oral argument that it is in the process of building a new state-of-the-art library outside the municipal complex,” the judges concluded. “Nothing in this opinion prevents the township from achieving that commendable goal.”

Monday’s ruling reverses the Appellate Division’s previous judgement.

Watch oral arguments for the case below via the NJ Supreme Court. You can read the court’s syllabus for the case underneath.

• See Related: West Orange Library Will Close, Move To New Location
• See Related: Temporary Location Opened For West Orange Public Library

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