PROPERTY - WISCONSIN

Blanc v. City of Janesville

Court of Appeals of Wisconsin - June 27, 2013 - Slip Copy - 2013 WL 3213297

This case involved a claim for relocation assistance and related benefits after the City of Janesville considered purchasing, but did not ultimately acquire, a property owned by Marc Blanc and rented by Schulz Automotive Machine, Ltd. Blanc and Schulz Automotive appealed an order granting summary judgment in favor of the City, which effectively denied Schulz Automotive’s claim for relocation assistance and Blanc’s claims for rental losses and legal expenses.

On appeal, Schulz Automotive argued that it met the definition of a “displaced person” and thus was entitled to relocation assistance. Blanc argued that he was entitled to recovery of rental losses and legal expenses under constitutional and estoppel theories.

The appeals court concluded that Schulz Automotive did not move from the property as a direct result of any circumstances set forth in WIS. ADMIN. CODE § ADM 92.01(14)(a) (Dec.2011) and thus is not a “displaced person” under the Wisconsin statutes and administrative code. It also concluded that Blanc was not entitled to rental losses or legal expenses under any of the theories on which he relied.



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