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08/02/06 Wilson/Glacier Mall Lawsuitattorneys at Law We mofds, WotfandSher-wood A ProfessionatLimitedLiability Tartnership Lznda M. Deola Brenda �inrf�ef.7�ali .7onatlran Jt Mod - ,lames r1'. 2ynolls �re<ferck �' Strerxuofld Debora![ S. Smik David -IT. W wilso4 ,7r. August 2, 2006 Mr. Charles Harball Kalispell City Attorney P. O. Box 1997 Kalispell, MT 59903 Re: Glacier Mall lawsuit Dear Mr. Harball: 401.Nortfr Last Chance tWlnf .7{elnq .iylantann r96D1 (406)442--3261 !2�at.. (406)443294 E'maik, 6afionormslaw. net I am the attorney representing the Plaintiffs in the lawsuit challenging the County Commissioners' decision approving the Growth Policy Amendment and zoning changes to allow construction of the Glacier Mall. As you probably are aware, earlier this year, the Montana Supreme Court issued a decision affirming Judge Stadler's ruling in part, but remanding the case to the District Court. It is my understanding that the City is considering amending the Kalispell Growth policy to allow similar uses on this property as were provided for in the county growth policy amendment and zoning of this property. I understand that as the city does not have planning jurisdiction in this area, this growth policy amendment would be triggered by a request annexing the area around the proposed Glacier Mall into the City. It is my further understanding that the County is assuming that with the Supreme Court's decision, the developers should be ready and able to proceed with the next step with the project. We have a different view of the impact of the Courts decision, however, and would ask you to review the decision. (North 93 Neighbors v. Board of County Commissioners, 2006 MT 132) Importantly, the Court found the Commissioners' approval of the growth policy amendment without taking into account public comment to be "unreasonable and an abuse of discretion." The Court then reversed and remanded: The District Court must evaluate whether the Board satisfied this obligation by requiring the Board to demonstrate what issues, if any, were raised through the public comment process that were not addressed by the Planning Office report. The Board must further demonstrate to the District Court that it evaluated such issues with the requirements of the Growth Policy.... We reverse and remand for this limited purpose. If the District Court determines that the Board failed to satisfy this obligation, or if the record proves insufficient to determine whether the Board complied, it should send the case to the Board for development of the factual record that it relied upon in making its decision. In other words, unless and until the Commissioners can demonstrate that they have met the Court's requirement that their decision reflect the public comment submitted following the issuance of the staff report, the legal status of the Growth Policy Amendment, and the zoning amendment that relied upon it; remains in doubt. As such, the still pending resolution of key issues in this suit awaits future court hearings and rulings. I would be happy to talk to you further about this matter. cc: North 93 Neighbors c�--i"avid K. W. Wilson, Jr. 2