VI.1. Resolution Upholding The Accommodation Specialist’s Denial Of The Request For Reasonable Accommodation For 101 Oakwood Road; Riggs CITY OF HOPKINS
City Council Report 2023-007
To:
From:
Date:
Subject:
Honorable Mayor and Council Members
Mike Mornson, City Manager
PeggySue Imihy Bean, AICP, Management Analyst
January 3, 2023
Resolution Upholding The Accommodation Specialist’s Denial Of The
Request For Reasonable Accommodation For 101 Oakwood Road
_____________________________________________________________________
RECOMMENDED ACTION
MOTION TO approve Resolution 2023-001 Upholding the Accommodation Specialist’s
Denial of the Request for Reasonable Accommodation to the Definition of the Family
Under the City Code for 101 Oakwood Road.
OVERVIEW
On June 10, 2022, the applicant, Mr. Kevin Stanton submitted a request for a reasonable
accommodation to allow for nine (9) occupants who are disabled due to alcoholism to live
at 101 Oakwood Road. Mr. Stanton currently operates the home at this address as a
sober living facility which is licensed by the City as a rental home for four (4) residents.
After review of the application and public comments, Staff determined that the request
was denied for the reasons outlined in detail in the letter of denial sent to the applicant on
October 7, 2022. The applicant, Mr. Stanton, has requested an appeal of this decision on
November 7, 2022, and the appeal was heard by the City Council on December 6, 2022.
At that time, the City Council directed Staff and the City Attorney to develop a findings of
fact for denial. The application, comments, and all information related to this application
can be found here.
Tonight, Staff has prepared a resolution affirming the denial in this matter to be reviewed
and approved by the City Council. Staff and the City Attorney will be available for any
questions.
SUPPORTING INFORMATION
•Resolution 2023-001 - Upholding the Accommodation Specialist’s Denial of the
Request for Reasonable Accommodation to the Definition of Family Under the City
Code for 101 Oakwood Road
Administration
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CITY OF HOPKINS
HENNEPIN COUNTY, MINNESOTA
RESOLUTION 2023-001
A RESOLUTION UPHOLDING THE ACCOMMODATION SPECIALIST’S DENIAL OF
A REQUEST FOR AN ACCOMMODATION TO THE DEFINITION OF FAMILY UNDER
THE CITY CODE FOR 101 OAKWOOD ROAD
WHEREAS, the applicant, Kevin Stanton (the “Applicant”), submitted a written request
for a reasonable accommodation for the property located at 101 Oakwood, Hopkins, MN
(the “Property”) in accordance with City Code, section 1-21; and
WHEREAS, the requested accommodation is from City Code, Part III, Chapter 102,
Article I., Sec. 102-4 – the definition of “family” – to allow nine unrelated individuals to
occupy one dwelling unit and City Code, Article V, Section 102-160 and 102-161 –
permitted uses per R Districts – to allow the operation of a sober home (the “Request”).
WHEREAS, the procedural history of the application is as follows:
1. On June 10, 2022, City staff received the reasonable accommodation Request
from Kevin Stanton – the application originally included information regarding
a variance request, which was later clarified and confirmed not to be a variance
request but instead was part of the reasonable accommodation Request;
2. On July 22, 2022, City staff sent the Applicant a letter confirming that a decision
would be made by October 8, 2022;
3. On October 7, 2022, the Accommodation Specialist issued her decision to deny
the Request as provided in Exhibit 1 to this Resolution;
4. On November 7, 2022, the Applicant requested that the City Council hear an
appeal of the Accommodation Specialists; and
5. On December 6, 2022, the Applicant presented his appeal to the City Council.
WHEREAS, the City Council, having heard the Applicant’s appeal and reviewed the
record in the present matter, makes the following determination pursuant to City Code,
section 1-21 (h).
NOW, THEREFORE, BE IT RESOLVED based on the information provided by the
Applicant, the Accommodation Specialist’s decision, and the entire record of the present
matter, the City Council hereby upholds the Accommodation Specialist’s denial of the
requested accommodation – to allow the Applicant to operate a sober home consisting of
up to nine unrelated persons residing together on the Property where the City Code allows
for no more than four – based upon the following findings of facts:
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1. Based upon the Applicant’s Request, the proposed use – a sober home – would
classify the Property as eligible for a reasonable accommodation under the Fair
Housing Act (“FHA”) and Americans with Disabilities Act (“ADA”) (collectively, the
“Act”). Specifically, houses which provide communal living to individuals with
alcohol addiction have been found to be eligible for reasonable accommodations,
as chemical dependency is generally a qualifying disability under the Act.
2. Pursuant to the Act, the Applicant bears the initial burden of establishing that their
request is both reasonable and necessary to afford disabled persons an equal
opportunity to housing. If the Applicant makes the requisite showing, the City may
consider evidence that the requested accommodation would constitute a
fundamental alteration to its policies, or in the zoning context the neighborhood,
and/or whether the requested accommodation would constitute an undue financial
or administrative burden on the City.
3. The Accommodation Specialist determined that the Request was not reasonable
or necessary, and also provided for the determination that the request would result
in a fundamental alteration to the City’s policies, the proposed use would result in
an inappropriate intensification of the current use of the Property, and that the
requested accommodation would constitute an undue financial or administrative
burden on the City.
4. The City Council specifically finds as follows:
a. The Applicant did not provide information establishing that the residents at
the Property would meet the definition of being disabled or handicapped as
defined in the Fair Housing Act (“FHA”) and Americans with Disabilities Act
(“ADA”). During the appeal process, the Applicant agreed to provide
screening criteria for future residents, however, the Applicant also never
addressed whether the fourth current resident meets the definition of being
disabled and never actually provided any screening criteria.
b. The Applicant did not provide adequate information showing that without
the accommodation that individuals who are disabled due to alcoholism will
not have the opportunity to live in the housing of their choice. The property
is currently being used as a sober home and denying the accommodation
does not result in individuals who meet the definition of being disabled due
to alcoholism being barred from the Interlachen Park neighborhood, any
particular zoning district, or the City of Hopkins.
c. The Applicant did not provide sufficient information to show that if the
accommodation is not granted, the business will not be financially viable.
The Applicant provided a table of expenses and revenues which shows that
rent charged is $650 per resident, but provided no additional justification as
to why $650 is reasonable and why nine individuals are necessary to make
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the Property financially viable. The Applicant also did not provide a
justification as to why $300 in reserves was reasonable. During the appeal,
the Applicant provided that $650 was the amount he believed was
reasonable based on his experience operating sober homes, but did not
provide any additional information. The Applicant did, inappropriately,
request that the Accommodation Specialist opine on the reasonableness of
the reserves included in the table of expenses – it is the Applicant’s
responsibility to show why the provided amount is necessary.
d. The Applicant did not provide that the increase was therapeutically
necessary. While increasing the number of individuals at a sober home is
proposed as being beneficial, the information provided does not establish
that increasing the number of individuals at the Property to nine is
necessary or even essential to the therapeutic environment at the Property.
Additionally, the anonymous letters purportedly from current residents state
that the sober home is operating successfully with four residents.
e. The Applicant has a history of attempting to skirt applicable regulations,
including with the City of Hopkins. This includes when the Applicant
purchased the Property in 2018 and subsequently began renting the
Property to more than the allowed number of residents without an
accommodation or rental license. Subsequently, the Applicant did obtain a
rental license but refused to allow the City to inspect the Property, as is
required as part of the rental license, and instead required the City to work
with his attorney, which required the City Attorney’s involvement, to
schedule the inspection.
f. Since the Applicant purchased the Property in 2018, there has been a 100%
increase in the number of police calls to the Property when comparing the
three years prior to the Applicant’s purchase (2014-2017) to the three years
since the purchase (2019-2022) – the City of Hopkins has seen a 7.62%
decrease and the Interlachen Park Neighborhood has seen an 11.46%
decrease in the number of police calls when comparing those same two
periods.
g. Granting the Request would result in a fundamental shift to the zoning
practices of the City by intensifying the allowed use to more than double the
number of individuals staying at the Property.
h. The Property may not be appropriate for a sober home because of the
current layout – the Property contains nine bedrooms, and it is not clear
whether residents would be able to share bedrooms, which is a noted and
important factor to recovery from alcoholism. Additionally, the Property has
not been inspected to determine whether the proposed layout is appropriate
for nine individuals to live based on applicable building code standards.
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i. The Applicant has provided that not more than five vehicles will be parked
at the property at any given time, however the Applicant previously
represented that current residents would not park on the street and
numerous community comments noted that this promise was not adhered
to. Additionally, the current layout of the Property is not suited to allow even
up to five vehicles to enter and exit the Property without coordination with
other drivers. This is concerning to the City because the next door neighbor
provided that a resident of the Property drove over the neighbor’s property
causing damage to the neighbor’s property, including to an inground
sprinkler system. Increasing the number of residents and number of cars at
the Property will not lessen the occurrence of parking issues.
j. Granting the requested accommodation would require the City to establish
a more rigorous and frequent inspection schedule, auditing the Applicant’s
compliance with the terms of the reasonable accommodation, and
establishing new criteria for a single property to ensure the safety of
residents and neighbors. These additional measures would be necessary
given the intensification of the use and the Applicant’s history of failing to
adhere to established health and safety requirements and his evidenced
history of lack of honesty. These necessary additional requirements would
result in a departure from established City policies.
k. The Applicant’s history of a lack of honesty and documented lack of control
is also concerning to the City, especially given that individuals in recovery
are generally considered to be a vulnerable population.
l. In response to the Accommodation Specialist’s decision, specifically the
inclusion of the Applicant’s history of lack of honesty, lack of control in
interactions with others, and inability to adhere to established health and
safety requirements, the Applicant claimed the City displayed animus
towards the Applicant. Ignoring the Applicant’s past actions would be a
dereliction of the City’s responsibility to protect the general safety and
welfare of all community members of the City of Hopkins. Including these
factors as part of determining whether the request for a reasonable
accommodation is prudent and does not evidence animus towards the
Applicant. If the Applicant’s argument were to be correct, the City could not
consider that the Applicant admitted to purchasing alcohol for a participant
in another sober home, which would be an absurd result.
m. The Applicant’s actions during the proceeding, including calling and
screaming at the Accommodation Specialist to change the applicant from
“Kevin Stanton” to “ninety n ninety LLC” and stating that he would “fire Kevin
Stanton” and apply using the LLC or a different name in an attempt to not
address his past behavior is concerning to the City and does not support
that granting the requested accommodation would be in the best interest of
public safety and welfare.
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5. Based on the foregoing, the City Council has determined that the requested
accommodation is neither reasonable nor necessary and is therefore denied.
Further, the City Council finds that if the accommodation request were reasonable
and necessary, the evidence supports a finding that the accommodation, if
granted, would constitute a fundamental alteration of the neighborhood and would
further create an undue administrative and financial burden for the City, and
therefore must be denied.
NOW, THEREFORE, BE IT FURTHER RESOLVED by the City Council of the City of
Hopkins that all recitals set forth in this Resolution are incorporated into and made part of
this Resolution, and more specifically, constitute the express findings of the City Council
and denial of the Applicant’s appeal.
Adopted by the City Council of the City of Hopkins this 3rd day of January, 2023.
By:___________________________
Patrick Hanlon, Mayor
ATTEST:
_______________________________
Amy Domeier, City Clerk