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HomeMy WebLinkAboutDecision on terms of Settlement with MMIA - combined materials Commission Memorandum REPORT TO: Honorable Mayor and City Commission FROM: Chris Kukulski, City Manager Greg Sullivan, City Attorney SUBJECT: Decision on Terms of Settlement with the Montana Municipal Interlocal Authority and Government Entities Mutual, Inc. in Cause No. DA-120311 (First Judicial District Court) MEETING DATE: December 10, 2012. AGENDA ITEM TYPE: Action. SUGGESTED MOTION: I hereby move to authorize the City Manager to execute a settlement agreement and release in substantial conformance with the terms outlined in the staff memorandum. BACKGROUND: This agenda item requests you consider the MMIA’s final offer of compromise in the declaratory judgment action the City filed against it and the MMIA’s reinsurer, GEM, over coverage of a $3 million damage award in Delaney v. City of Bozeman. If acceptable, I ask you authorize the City Manger to execute a final agreement in substantial conformance with the terms of settlement listed below. A suggested motion is provided below. This memorandum does not provide discussion on the underlying litigation which began in 2003 and was finalized with a decision by the Montana Supreme Court in December of 2009. Also, because all the parties to this litigation are public entities your discussion must be open to the public. Commission decisions on accepting settlements must be open to the public as a matter of law. In the early spring of 2010, you authorized the filing and serving a declaratory judgment action to resolve a legal dispute between the City and the MMIA/GEM regarding whether the MMIA was obligated to provide coverage for the entire Delaney damage award. The complaint is attached. Judge Seeley ruled in favor of the MMIA on the grounds that the City had financially gained from the purchase of the Mandeville Farm property denying coverage. Judge Seeley’s decision is also attached. The City has appealed Judge Seeley’s decision to the Montana Supreme Court. Over the past several months as part of the Supreme Court’s mandatory settlement mediation, the City Manager, Commissioner Taylor, Beth O’Halloran (retained counsel), and myself have discussed settlement with the MMIA. Out of those discussions the MMIA has issued its final offer of compromise. The MMIA’s final proposal includes the following terms: 1. The City shall reimburse the MMIA1 in the principal amount of $2 million in three equal installments: the first of which shall occur no later than January 15, 2013, in the amount of $666,666.00 (plus interest noted below); the second of which shall occur no later than July 15, 2013, in the amount of $666,666.00 (plus interest noted below); and the third of which shall occur no later than July 15, 2014, for the remaining portion of the Settlement Amount (plus interested noted below). 2. Each payment will include interest on the remaining principal amount, compounded monthly at the rate of 1.0% annual interest, commencing with the date of execution of this Agreement by all parties. The City may prepay any amount without penalty. 3. The City agrees to reimburse the MMIA up to $1,000,000.00 (one million dollars) if the City sells the Property (defined in the agreement by its legal description) for a profit. Any reimbursement shall occur on a 2/3 City and 1/3 MMIA basis. A “profit” shall occur only when the City has recovered its total investment in the Property2 , which includes the original purchase price together with all “Costs of Development” which shall include the following: those costs and fees, whether incurred prior to or after execution of the settlement agreement, related to: engineering; grading and site preparation; utilities and their installation; roads, curbs, gutters, stormwater; and sidewalks/pedestrian walkways. 4. If the City ever sells the Property, the City will provide the MMIA an accounting of all “Costs of Development” the City claims as part of its investment, when the proceeds are distributed. 5. The City may not be prevented from selling or transferring ownership of the property to any entity, nor shall this Agreement preclude the City from selling or transferring ownership of the property to an economic development authority for less than the purchase price. Further, the terms of the Agreement do not run with the land, nor shall they constitute an encumbrance on the title of the property. 1 The MMIA paid the $3million Delaney judgment pursuant to an agreement that will require the City to reimburse the MMIA for any amount agreed to in settlement. 2 The “Property” consists only of the real property purchased by the City in 2003 that lead to the underlying litigation. 6. The City will release both the MMIA (including its counsel in the declaratory judgment action) and GEM (including its counsel in the declaratory judgment action). In addition, the MMIA is requiring as a term of settlement the City release the MMIA’s general counsel, Browning, Kaleczyc, Berry, and Hoven, P.C. The MMIA is requiring the release of these entities to include all future claims related to the declaratory judgment action and those related to the handling of the Delaney action. UNRESOLVED ISSUES: Should you adopt a motion approving the settlement, a final settlement agreement and release in substantial conformance with the above will need to be developed and executed by the City Manager. The City may pursue claims for professional negligence against the law firm that represented the City in the underlying litigation. ALTERNATIVES: As the final offer of compromise is open only until 5:00 PM, Tuesday, December 11, 2012, the options for the Commission are limited. The Commission may accept the proposal or reject the proposal. FISCAL EFFECTS: During budget development and adoption for FY2013, the Commission reviewed and discussed financial plans in the event the City was required to pay the full $3 million judgment (see Commission Memo, June 11, 2012, “Fiscal Year 2013 (FY13) Budget Work Session – General Fund). On the attached document (Settlement Option #3 – Revised) we have updated this previous financial information to illustrate how the proposed settlement would affect the City’s current and future General Fund Reserves. The City’s proposed $2 million share of Delaney damage award, the interest charged by the MMIA, and the timing of payments are reflected on the attached Settlement Option #3 – Revised. Accepting this settlement will require the General Fund to pay approximately $2,013,000.00 over fiscal years, 2013, 2014, and 2015. The City’s estimated General Fund Reserve would remain above the minimum according to the described plan. Attachments: • Complaint for Declaratory Judgment, City of Bozeman v. MMIA & GEM. • Judge Seeley’s Decision on Summary Judgment, City of Bozeman v. MMIA & GEM. • Settlement Option #3 - Revised THE CITY OF BOZEMAN, Plaintiff, V. MONTANA MUNICIPAL INTERLOCAL AUTHORITY and GOVERNMENT ENTITIES MUTUAL, INC., Defendants. Cause No. CDV-2010-395 MEMORANDUM AND ORDER ON MOTIONS FOR SUMMARY JUDGMENT DEPUTY MONTANA FIRST JUDICIAL DISTRICT COURT LEWIS AND CLARK COUNTY Plaintiff City of Bozeman (City) filed a complaint for declaratory judgment seeking a determination of responsibility for payment of a $3,000,000 judgment entered against the City in Delaney and Co., Inc. v. City of Bozeman, Gallatin County Cause No. DV-03-354. Defendants Montana Municipal Interlocal Authority (MMIA) and Government Entities Mutual, Inc. (GEM), have answered, and all parties have filed motions for summary judgment. The motions have been briefed and were orally argued on September 22, 2011. The Court will resolve all motions in ///// 1 2 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CC 0-`5\fr 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this single Order. The Court concludes that the City's motion should be denied, and the motions of MMIA and GEM should be granted. STANDARD OF REVIEW Summary judgment is appropriate when "the pleadings, the discovery and disclosure materials on file, and any affidavits show that there is no genuine issue as to any material fact and that the movant is entitled to judgment as a matter of law." Rule 56(c)(3), M.R.Civ.P. The party moving for summary judgment must establish the absence of any genuine issue of material fact and entitlement to judgment as a matter of law. Tin Cup County Water and/or Sewer Dist. v. Garden City Plumbing, 2008 MT 434, ¶ 22, 347 Mont. 468, 200 P.3d 60. Once the moving party has met its burden, the party opposing summary judgment must present affidavits or other testimony containing material facts that raise a genuine issue as to one or more elements of its case. Id., 411 54 (citing Klock v. Town of Cascade, 284 Mont. 167, 174, 943 P.2d 1262, 1266 (1997)). Conclusory statements and assertions will not prevent summary judgment. Id. In this instance, the parties agree there are no material issues of fact tobe decided. The issues before the Court involve questions of law — the interpretation of the Memorandum of Liability Coverage. DISCUSSION Delaney and Company, Inc. (Delaney), is a Montana corporation and property developer in the Bozeman area. In 2003, Delaney was negotiating with Lloyd Mandeville to purchase property for a development that was to include a waste transfer station site. Delaney and Mandeville agreed on a price per acre for the property, and Delaney then made additional arrangements in furtherance of the development. MEMORANDUM AND ORDER ON MOTIONS FOR SUMMARY JUDGMENT — Page 2 Delaney discussed his development plans with the Bozeman city manager. The city manager told Delaney that he would review the plans and provide Delaney with waste transfer station design layouts. Instead, the city manager undertook negotiations to purchase the property on behalf of the City without Delaney's knowledge. The City ultimately purchased the property, and Delaney filed suit against it, alleging constructive fraud, negligent misrepresentation, and intentional interference with prospective economic advantage. During the course of the litigation, the district court held that, as a sanction for discovery abuses, the City was liable to Delaney. The matter then proceeded to jury trial on the issue of damages. The jury awarded $3,000,000 to Delaney for lost profits, and the verdict was affirmed on appeal. Delaney & Co. v. City of Bozeman, 2009 MT 441, 354 Mont. 181, 222 P.3d 618. MMIA, a public entity risk pool to which the City belongs, paid the judgment under a reservation of rights conditioned on a judicial determination of which party or parties — the City, MMIA, and/or its reinsurer, GEM — are ultimately responsible for payment of the judgment. MMIA's coverage has a limit of $750,000 for each claim, with a $1,500,000 limit for each occurrence. GEM reinsures above those limits for claims not subject to the tort claim limitations of Section 2-9-108, MCA. In Delaney, the district court determined that the judgment against the City was not subject to the statutory limits, and this determination was upheld on appeal. Id., 25. The City contends that MMIA is responsible for payment of the judgment pursuant to the terms of the Memorandum of Liability Coverage issued to 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MEMORANDUM AND ORDER ON MOTIONS FOR SUMMARY JUDGMENT— Page 3 the City for the time period at issue. Both MMIA and GEM seek a determination that there is no coverage for the Delaney judgment as a matter of law. Although MMIA is not an insurance provider in the usual sense, the Montana Supreme Court has applied principles of insurance policy interpretation to coverage disputes relating to MMIA indemnity agreements with municipalities. See, e.g., Town of Geraldine v. Mont. Mun. Ins. Auth., 2008 MT 411, 118, 347 Mont. 267, 198 P3d. 796. An insurance contract is construed according to the general principles of contract law: General rules of contract law apply to insurance policies and we construe them strictly against the insurer and in favor of the insured. Courts give the terms and words used in an insurance contract their usual meaning and construe them using common sense. Any ambiguity in an insurance policy must be construed in favor of the insured and in favor of extending coverage. An ambiguity exists where the contract, when taken as a whole, reasonably is subject to two different interpretations. Courts should not, however, "seize upon certain and definite covenants expressed in plain English with violent hands, and distort them so as to include a risk clearly excluded by the insurance contract." Travelers Cas. & Sur. Co. v. Ribi Immunochern Research, Inc., 2005 MT 50, It 17, 326 Mont. 174, 108 P.3d 469 (citations omitted). A contractual ambiguity does not exist simply because one party claims to perceive language as ambiguous. The supreme court recently reaffirmed this principle, stating: A contract provision is ambiguous if it is susceptible, without violence, to more than one reasonable interpretation. Whether a provision is ambiguous is a question of law, which courts resolve from the viewpoint of the layperson "untrained in the law or the insurance business." "Ambiguity does not exist just because a claimant says so," or just because the parties disagree as to the meaning of the contract provision. ///// ///// ///// 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MEMORANDUM AND ORDER ON MOTIONS FOR SUMMARY JUDGMENT — Page 4 Further, courts will not distort contractual language to create an ambiguity where none exists. Giacornelli v. Scottsdale Ins. Co., 2009 MT 418, ¶ 32, 354 Mont. 15, 221 P.3d 666 (citations omitted). The language of a contract governs its interpretation if it is clear, explicit and does not involve an absurdity. Section 28-3-401, MCA. If the words of a contract are "clear, certain, and unambiguous, the language alone controls and there is nothing for the courts to interpret or construe." Morning Star Enters. v. R.H. Grover, 247 Mont. 105, 111, 805 P.2d 553, 557(1991); Section 1-4-101, MCA. The Court concludes that the issue to be resolved in this case does not involve a contractual ambiguity; rather, the question is whether the language of the relevant exclusion negates coverage. In support of its motion for summary judgment, the City sets forth a detailed analysis of the provisions of the Memorandum of Liability Coverage it contends obligates MMIA. Essentially, the City asserts that coverage exists under the property damage or public official errors and omissions clauses of the memorandum. It points out that the threshold factors required to generate coverage are a finding of damages resulting from property damage, or by errors and omissions caused by an occurrence as those terms are defined in the policy. According to the City, the damages awarded by the jury were directly tied to Delaney's claims of constructil'ie fraud, negligent misrepresentation and intentional interference with prospective economic damage. Citing Town of Geraldine, GEM points out that the Montana Supreme Court has "repeatedly held that it is the acts giving rise to the complaint which form the basis for coverage, not the complaint's legal theories or conclusory language." 1 2 3 4 5 6 7 8 9 10 •11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MEMORANDUM AND ORDER ON MOTIONS FOR SUMMARY JUDGMENT — Pages Town of Geraldine,1124. GEM asserts that because all of the conduct alleged in the complaint was intentional and willful, no matter how it may be stylized legally, it does not fit within the definition of an "Occurrence" as that term is defined in the memorandum. The relevant portions of that definition state: "Occurrence" - - means: 1. With respect to Bodily Injury or Property Damage, an accident or event which results during the COVERAGE PERIOD, in Bodily Injury or Property Damage neither expected nor intended from the standpoint of the Covered Party, . . . 3. With respect to Public Officials Errors and Omissions, actual or alleged conduct during the Coverage Period as described in the definition of Public Officials Errors and Omissions. (MMIA's Mem. Supp. Mot. Summ. J., Ex. 1, at 4 of 20.) The definition of "Public Officials Errors and Omissions" referred to in subparagraph 3 states that it "means any act, omission, neglect, or breach of duty, including nonfeasance, misfeasance, and malfeasance by the COVERED PARTY." (Id., at 5 of 20.) GEM maintains that in terms of the public officials errors and omissions provision, if the acts of the covered party are intentional or deliberate, they are excluded from coverage. It notes that the Delaney complaint did not allege an "occurrence" but rather willful and intentional misconduct. Moreover, it argues that the City's claims under the property damage provisions of the memorandum render the errors and omissions claims irrelevant because they are mutually exclusive according to the terms of the Memorandum of Liability Coverage. Both GEM and MMIA acknowledge that the City is covered presumptively under the language of the memorandum that describes general grants of authority. However, they assert that the broad areas of coverage are subject to the exclusions. GEM and MMIA also maintain that because the City still owns the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MEMORANDUM AND ORDER ON MOTIONS FOR SUMMARY JUDGMENT — Page 6 property, it has suffered no loss or damage as those terms are defined in the memorandum. Relying on exclusion 23, they argue that the Delaney judgment constitutes a financial gain to which the City was not entitled. The exclusion states: "Any liability of the COVERED PARTY arising in whole or in part out of the COVERED PARTY obtaining remuneration or financial gain to which the COVERED PARTY was not legally entitled." (Id., at 11 of 20.) GEM also avers that exclusion 24, or at least the first paragraph thereof, applies as well. It states that coverage is excluded for lalny liability arising out of any deliberately dishonest or fraudulent act or omission, or any criminal or malicious act or omission, or any willful violation of the law." (Id., at 11 of 20.) The City proffers the "reasonable expectations" doctrine as a basis for avoiding the exclusions for deliberate dishonesty and willful statutory violation. This concept is explained in Hanson v. Employers Mut. Gas. Co., 336 F. Supp. 2d 1070, 1075 (D.Mont, 2004): The reasonable expectations doctrine provides that the objectively reasonable expectations of insurance purchasers about the terms of their policies should be honored even if a painstaking study of the policy would negate those expectations. An insurance contract is to be interpreted from the viewpoint of a consumer with average intelligence, with no training in law or insurance. (Citations omitted.) MMIA and GEM assert that the reasonable expectations doctrine has no application to the situation in this case because the City is not an average insurance consumer. Instead, it is one of the founding members of MMIA, has held a seat on its board of directors since its inception, and signed the most recent MMIA liability program agreement in 2009. The City is a member of a pool of self-insured — all sharing responsibility for claims made against the Authority. The nature of this type 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MEMORANDUM AND ORDER ON MOTIONS FOR SUMMARY JUDGMENT — Page 7 of organization was discussed in City of Arvada v. Colorado Intergov 'ti Risk Sharing Agency, 19 P.3d 10, 13 (Colo. 2001), in which the Colorado Supreme Court observed: Mnsurance pools do not undertake the indemnification of a third party. Rather, an insurance pool is, in essence, an extension of each member, as the funds that provide the coverage come directly from the members, and the type and extent of coverage is determined collectively by the members themselves. Thus, self-insurance pools are more properly likened to simple self-insurance than to insurance companies. After consideration of the arguments of all parties, the Court concludes that coverage is excluded under exclusion 23. For this reason, it need not address application of exclusion 24. The Montana Supreme Court decisions in Delaney and City of Dillon v. Mont. Mun. Ins. Auth., 2009 MT 393, 353 Mont. 370, 220 P.3d 623, are instructive. City of Dillon involved a question of whether interest earned on wrongfully retained pension benefits, was "financial gain" as that term appeared in a policy exclusion identical to exclusion 23 in this matter. The court held that it was, and stated: The District Court held that while the Williams claim was a covered loss, the clause referred to as the "financial gain" exclusion precluded coverage. The District Court applied the "financial gain" exclusion only to Williams' claim for the principal amount of her unpaid pension benefits, but declined to apply it to Williams' claim for interest. This approach construes and applies the "financial gain" exclusion too narrowly, and in contravention of its plain language. The exclusion, as noted above, provides that there is no coverage for lalny liability" of Dillon that arises "in whole or in part" from Dillon's obtaining money that it is not entitled to. The clear and explicit language of a contract governs its interpretation, § 28-3-401, MCA, and the words are to be understood in their ordinary and popular sense, § 28-3-501, MCA. The unambiguous plain language of an insurance policy coverage exclusion is applied. We therefore apply the plain language of the MMIA memoranda governing exclusions from coverage. Id., 11112, 13 (citation omitted). ///// 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MEMORANDUM AND ORDER ON MOTIONS FOR SUMMARY JUDGMENT — Page 8 The City contends that the Delaney judgment does not represent financial gain to the City — instead it constitutes lost potential profits to Delaney. As such, in the City's view, exclusion 23 does not apply. Viewed from this perspective, any future financial gain that may be realized by the City is irrelevant when considering the application of the exclusion. However, as the Montana Supreme Court decision recognizes, the award made to Delaney was based on the testimony of the City's own expert, who established his calculation based upon what the City could realize as profit from the property. That decision states: Delaney presented the testimony of a consultant who had been retained by Bozeman to assist the city in preparing a master plan for the development of the Mandeville property. His work included an economic analysis and a feasibility study of various ways in which the property could be developed. His analysis predicted a profit to Bozeman of $ 3,000,000, which was ultimately the amount of the jury's verdict. 1 2 3 4 5 6 7 8 10 11 12 Delaney, IT 35. The City argues that the supreme court's decision in City of Dillon is "inapposite" to the situation in Delaney, primarily because in City of Dillon there was a conversion of property not present in the instant case. The City asserts: It is the conduct associated with the acquisition of property, not the holding of the property itself, that supported Delaney's three claims... These claims are based upon the conduct of the City of Bozeman officials in pursuing legitimate title to real property when the actual title was held by Mandevilles, not Delaney and Company. (Combined Br. Resp. MMIA's & GEM's Brs. Supp. Mots. Summ. J., at 7.) However, the City's characterization fails to acknowledge two salient factors. The first is that City of Dillon does not limit the application of the language in exclusion 23 to situations only involving conversion; conversion was simply the underlying factual circumstance in that case. The second is that the verdict in Delaney represents what the jury considered to be wrongful, willful conduct by a city official 13 14 15 16 17 18 19 20 21 22 23 24 25 MEMORANDUM AND ORDER ON MOTIONS FOR SUMMARY JUDGMENT — Page 9 resulting in the City obtaining financial gain to which it was not legally entitled. The supreme court recognized this fact in affirming the district court when it stated: "In this case, Bozeman tortiously interfered with Delaney's ability to acquire the Mandeville property, causing Delaney to suffer a loss of profits." Delaney, IT 24. Attached as an exhibit to the City's combined response brief to MMIA' s and GEM' s motions for summary judgment is the affidavit of Chris Kukulski, Bozeman city manager, which contains a statement that the City paid $3,057,000 for the Mandeville property and that, as of the date of the affidavit, the City has realized no financial gain from the acquisition. However, that situation is irrelevant to the issue of whether MMIA is obligated to assume the debt. Delaney affirmed a jury instruction that stated in part: "Your award should include lost profit or other prospective gain from the operation of Delaney & Company's business, which in this case was the purchase and development of the Mandeville Ranch property." Id., ¶ 39. As MMIA points out in its reply brief, the Delaney judgment represents profit to Delaney lost to the City after expenditures made in pursuit of that profit. In Ophus v. Fritz, 2000 MT 251, 1124, 301 Mont. 447, 11 P.3d 1192, the supreme court relied on the two dictionary defmitions to define profit: "Profit" is defined in Black's Law Dictionary as "the excess of revenues over expenditures in a business transaction." BLACK'S LAW DICTIONARY 1226 (7th ed. 1999). Likewise, Webster's dictionary defines "profit" as "the excess of the selling price of goods over their cost." WEBSTER'S NEW AMERICAN DICTIONARY 415 (1995). What the City gained and Delaney lost was the projected $3,000,000 over the expenditures incurred in obtaining and developing the property, according to the testimony of the City's own expert. That gain was only realized through the ///// 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MEMORANDUM AND ORDER ON MOTIONS FOR SUMMARY JUDGMENT — Page 10 tortious actions of the City, which still retains the property and thus the future profit-value of the property. In SAFC0 Ins. Co. v. Liss, 2000 MT 380, ¶ 30, 303 Mont. 519, 16 P.3d 399, the Supreme Court noted that "well-established" public policy precludes indemnification of willful acts. It would be contrary to public policy in this case to require the insurers to pay the City for acts that were determined to be wrongful as a matter of law. Based on the foregoing, IT IS HEREBY ORDERED that the City's motion for summary judgment is DENIED. The motions for summary judgment of MMIA and GEM are GRANTED. DATED this day of April 2012. 6:44,704621e-, KATIlY SE EY Distri t CourijJudge pc: Elizabeth A. O'Halloran Curt Drake Joe Seifert T/ICS/bozeman v mont municip auth m&o mots summ j.wpd 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MEMORANDUM AND ORDER ON MOTIONS FOR SUMMARY JUDGMENT — Page 11 Settlement Option #3 ‐ Revised for Commission Comments and Updated Financial InformationGeneral Fund Reserve FY13 Budget FY14 Estimate FY15 EstimateNotes:Fiscal Year  Ending Balance 5,578,416           6,608,416         6,434,294         From the FY13 Appropriation Resolution, plus FY12 Updated Ending BalanceAmend:  MMIA Settlement (667,000)           (674,122)         (672,660)           Per Current Proposed SettlementAmend:  Fair Housing Settlement (150,000)           Tax Estimate vs. Certified Amount (68,000)             FY13 Budget HOLD ‐ Capital ‐ PD Design Costs 250,000            FY13 Budget HOLD ‐ Capital ‐ Bogert Pool Maintenance/Design 177,000            FY13 Budget HOLD ‐ Capital ‐ Lindley Park Restroom Replacement 175,000            SID Revolving Fund excess ‐ TRANSFER 613,000              Would still leave 2x the statutory minimum in the fund, plus money for future road projects.FY13/14 Unspent Budget Authority and Revenues 700,000            500,000          Known each Sept following the Fiscal Year end.Adjusted Balance 6,608,416         6,434,294       5,761,634         Adopted Minimum 16.67% 3,862,238          4,031,581        4,031,581         Difference for Adopted Budget Purposes 1,702,713         1,230,053         Indicates whether a Special Budget Hearing is likely needed to be needed