CIVIC JC, INC. VS. THE CITY OF JERSEY CITY (L-3633-15, HUDSON COUNTY AND STATEWIDE), A-4356-15T3

Civic JC challenged Jersey City's designation of a 2.2-acre City Hall Study Area (City Hall, two adjacent parking lots, and a nearby 3‑story residential building) as a "non-condemnation area in need of redevelopment" under the LRHL, N.J.S.A. 40A:12A-1 to -73.
Senior Planner Mary Ann Bucci-Carter conducted a survey and prepared a written Report finding all parcels in "poor" condition and describing obsolescence, dilapidation, safety defects, and lack of modern systems and drainage.
The Planning Board held a public hearing (Civic JC did not attend), unanimously recommended designation, and the Municipal Council adopted the designation.
Civic JC sued in lieu of prerogative writs seeking invalidation, arguing (1) "obsolescence" requires non-use, so occupied buildings cannot qualify, and (2) the Report lacked evidence that conditions were "conducive to unwholesome" conditions or "detrimental to safety, health, morals, or welfare."
The trial court, applying deferential review, found the designation supported by Bucci-Carter's Report and testimony and denied relief; the Appellate Division affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether buildings in use can be "obsolescent" under LRHL §5	Obsolescence means "no longer in use," so occupied buildings cannot qualify	Obsolescence means becoming outdated; in‑use buildings can be obsolescent	Court: Obsolescence does not require non‑use; designation may be based on obsolescence
Whether the Report provided substantial evidence of criteria (a) and (d) (obsolescence/dilapidation; detrimental conditions)	Report failed to address the "conducive to unwholesome" or "detrimental" elements adequately	Report and planner testimony documented specific unsafe, substandard, and obsolete conditions across parcels	Court: Report + unrebutted testimony constituted substantial evidence; designation not arbitrary or capricious
Whether the court may parse components of a property (e.g., parking lot separate from building) when evaluating LRHL criteria	Civic JC urged separate consideration of structures/uses	Defendants relied on treating Study Area as an integrated whole in analysis	Court: May not parse; must evaluate area as an integrated whole; parking lots properly considered in overall finding
Adequacy of administrative factfinding when plaintiff did not present contrary evidence at hearing	Lack of interior inspection or direct contest undermines Report	Planner relied on exterior survey and owner‑provided info; no rebuttal presented at hearing	Court: Unrebutted professional report and testimony suffice as substantial evidence

62-64 Main Street, LLC v. Mayor & Council of City of Hackensack, 221 N.J. 129 (2015) (LRHL blight‑designation standards and limits on parsing property components)
Jacoby v. Zoning Bd. of Adjustment of Borough of Englewood Cliffs, 442 N.J. Super. 450 (App. Div. 2015) (deference to local board factual findings)
Levin v. Township Committee of Bridgewater, 57 N.J. 506 (1971) (presumption of validity for municipal determinations)
Concerned Citizens of Princeton, Inc. v. Mayor & Council of Borough of Princeton, 370 N.J. Super. 429 (App. Div. 2004) (statutory effect of substantial‑evidence support for redevelopment designations)