Hartford, Connecticut
In 1990, the Hartford Redevelopment Agency (HRA) adopted a redevelopment plan that would allow the City to condemn privately owned land for redevelopment. The crux of the plan was that the HRA would consolidate parcels of property and then sell them to developers willing to rehabilitate them. The redevelopment area included two parcels that local resident Frank Citino had purchased in 1985 with the intention of renovating an apartment building located there. The HRA even told Citino that he could retain his land if he rehabilitated it. However, Citino’s plans to renovate one of the parcels were rejected, and the agency eventually responded by condemning it instead. Over time, the HRA acquired all of the land in the redevelopment area except Citino’s second parcel. By the time Citino fully rehabilitated the building, the HRA had already cleared out all the residents of the buildings in the surrounding area. The City simply boarded them up and allowed them to deteriorate. Consequently, Citino was only able to rent out two of the six apartments in the renovated building.
Citino successfully sued the redevelopment agency, and the court found that the condemning authority’s failure to implement its redevelopment plan in a reasonable amount of time, coupled with its permitting the overall deterioration of the surrounding area in the interim, was, for all intents and purposes, a condemnation.[1] Meanwhile, the City’s “redevelopment” project remained a complete failure, which, for years, resulted only in deterioration and empty buildings.[2] Finally, in the fall of 2003—13 years after the City adopted its redevelopment plan—the Park Squire Wolcott commercial and residential development opened, giving the City something to show for a project that failed to produce any benefit for more than a decade.[3]
[1] Citino v. Hartford Redevelopment Agency, 721 A.2d 1197, 1209-10 (Conn. App. 1998).
[2] Dana Berliner, Public Power, Private Gain: A Five Year, State-By-State Report Examining the Abuse of Eminent Domain (2003), available at http://www.castletrans.wpengine.com/report (June 19, 2006).
[3] “Case Study #2: Trinity College – Hartford Connecticut,” University and College Community Partnerships, University of Nevada, Reno, Comprehensive Master Plan, March 11, 2004.