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Cases of Interest

Chuck Thompson

Tue, Apr 1, 2025 3:14 PM

7th Circuit - Reverse Discrimination - Right to Sue - Improper Defendant
It's quite astounding to see folks who have licensed attorneys sue entities of state or local government that cannot sue or be sued. Such was the case here where a reverse discrimination claim sought to hold accountable the Marion County Prosecutor's Office for an equal protection violation. But, was the "office" a "person" under the state law? No, the office was not an independent entity under state law that could be sued under state law nor could it be considered a "person" under the Civil Rights Act. Another obstacle the Plaintiff could not overcome in her Title ViI claim stood the 90 day requirement to file suit after receiving a right to sue letter. She received the letter via email but did not open it until the next day. She filed suit 91 days after receipt and 90 days after opening it. Too late!
Kiinder vs. Marion County Prosecutor's Office, processWebInputExternal.plhttps://media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2025/D03-26/C:24-1952:J:Brennan:aut:T:fnOp:N:3351133:S:0

Be aware: If someone sues your police department or another department of your local government determine if the entity is one that can be sued; i.e., is it a "person", can it be sued by virtue of a statutory provision under state or local law. Consider raising the issue after limitations have passed.

6th Circuit - Taxes - Fifth Amendment - Tax Sales
Michigan has dealt with issues arising from its tax sale process for several years. After learning that its process, including forfeiting surplus proceeds from the sale to the government, failed Constitutional muster, the state amended its laws to bring them into compliance. The Plaintiff in this case sought to recover surplus proceeds from a sale, but did not follow the procedures established under the new laws. Can she recover - no. The Plaintiff failed to act as required by the law to seek to recover the surplus proceeds in a timely manner. Recognizing the problem, the Plaintiff raised the issue that under Knick v. Township of Scott, 588 U.S. 180 (2019), she need not file anything to protect her property against expropriation by the government. The Court replied:" But unlike the state laws at issue in Knick, Michigan's procedures for collecting the surplus do not compensate the property owner for a taking. They prevent a taking from happening in the first place. A county that allows property owners to obtain any surplus after a foreclosure and keeps the residual only if the owners do not seek it does not commit a taking. See Nelson, 352 U.S. at 110; see also Tyler, 598 U.S. at 644. Had Howard followed the Act's procedures for claiming the surplus, only to be denied it, then she could immediately bring a takings claim under § 1983. That is all that Knick guarantees."
Howard vs. Macomb County, MI, 25a0070p-06.pdfhttps://www.opn.ca6.uscourts.gov/opinions.pdf/25a0070p-06.pdf

FWIW: This case may rear its ugly head as a cert petition to the SCOTUS and may be the type of case the libertarian and a couple of conservatives would enjoy.

9th Circuit - RLUIPA - Matters of Law
Church buys agriculturally zoned land and applies for a special use exception to build a church (ever heard that before). Special Exception is denied and church sues. Case goes to trial. Court instructs jury on the question of government imposing a "substantial burden" on a person's or religious institution's "religious exercise" unless the burden is the least restrictive means of furthering a compelling government interest and ask the jury to decide if such were the case when the special exception was denied. The jury sides with the county and concludes it did not impose a substantial burden on the church's religious exercise. On appeal, a really upset church claims the lower court should not have given the instruction as it did. A minor skirmish ensued over whether that argument was waived and whether the Defendants waived making the waiver argument. But as the sun came up over Maui the panel concluded that the issue was really a matter of law, the judge should have decided the question but since the jury decided it the way the judge should have decided it, no harm no foul and the lower court judgement was affirmed. So, surf's up - go hang ten.
Spirit of Aloha Temple vs. County of Maui, 23-3633.pdfhttps://cdn.ca9.uscourts.gov/datastore/opinions/2025/03/28/23-3633.pdf

Charles W. Thompson, Jr.
Of Counsel
P: (202) 466-5424 x7110
M: (240) 876-6790
D: (202) 742-1016
[facebook icon]https://www.facebook.com/InternationalMunicipalLawyersAssociation/[twitter icon]https://twitter.com/imlalegal[linkedin icon]https://www.linkedin.com/company/international-municipal-lawyers-association-inc./

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Michigan - Supreme Court - Taxes - Statutory Interpretation - Due Process For those of you unacquainted with the Michigan Supreme Court (and I'm one of you), the court issues opinions and like the SCOTUS includes a headnote of its opinion. Unlike the SCOTUS the drafters of the headnote in Michigan are not familiar with the common writing tool often called "a paragraph" nor do the drafters consider brevity to be the soul of wit. Thus, the headnote is probably denser than the opinion itself. Having waded through the headnote and leaving aside Michigan specific substantive issues, that leaves us with due process. The case involves a company that sought a tax exemption. The statute provides the method for applying for and appealing decisions regarding these exemptions. The statute specifies what notice the taxpayer should receive. The administrative tribunal charged with hearing these appeals concluded it lacked jurisdiction to adjudicate the issues because the appeal was not timely filed. Michigan's intermediate court reversed concluding the notice given to the taxpayer was inadequate despite being complicit with the statute as the intermediate court in the "hand holding" mode felt the notice could have been more clear and explicit. The Supreme Court felt otherwise concluding due process was not violated as the taxpayer had actual notice of the filing requirements and that the notices given; albeit bare, were compliant with the law. (Apologies to all if my ability to synopsize what occurred missed something). SIXARP, LLC v TOWNSHIP OF BYRON, MSC 166190 SIXARP LLC V TOWNSHIP OF BYRON Opinion on Application - Reverse CoA 3/26/2025<https://www.courts.michigan.gov/siteassets/case-documents/uploads/OPINIONS/FINAL/SCT/166190_43_01.pdf> 7th Circuit - Reverse Discrimination - Right to Sue - Improper Defendant It's quite astounding to see folks who have licensed attorneys sue entities of state or local government that cannot sue or be sued. Such was the case here where a reverse discrimination claim sought to hold accountable the Marion County Prosecutor's Office for an equal protection violation. But, was the "office" a "person" under the state law? No, the office was not an independent entity under state law that could be sued under state law nor could it be considered a "person" under the Civil Rights Act. Another obstacle the Plaintiff could not overcome in her Title ViI claim stood the 90 day requirement to file suit after receiving a right to sue letter. She received the letter via email but did not open it until the next day. She filed suit 91 days after receipt and 90 days after opening it. Too late! Kiinder vs. Marion County Prosecutor's Office, processWebInputExternal.pl<https://media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2025/D03-26/C:24-1952:J:Brennan:aut:T:fnOp:N:3351133:S:0> Be aware: If someone sues your police department or another department of your local government determine if the entity is one that can be sued; i.e., is it a "person", can it be sued by virtue of a statutory provision under state or local law. Consider raising the issue after limitations have passed. 6th Circuit - Taxes - Fifth Amendment - Tax Sales Michigan has dealt with issues arising from its tax sale process for several years. After learning that its process, including forfeiting surplus proceeds from the sale to the government, failed Constitutional muster, the state amended its laws to bring them into compliance. The Plaintiff in this case sought to recover surplus proceeds from a sale, but did not follow the procedures established under the new laws. Can she recover - no. The Plaintiff failed to act as required by the law to seek to recover the surplus proceeds in a timely manner. Recognizing the problem, the Plaintiff raised the issue that under Knick v. Township of Scott, 588 U.S. 180 (2019), she need not file anything to protect her property against expropriation by the government. The Court replied:" But unlike the state laws at issue in Knick, Michigan's procedures for collecting the surplus do not compensate the property owner for a taking. They prevent a taking from happening in the first place. A county that allows property owners to obtain any surplus after a foreclosure and keeps the residual only if the owners do not seek it does not commit a taking. See Nelson, 352 U.S. at 110; see also Tyler, 598 U.S. at 644. Had Howard followed the Act's procedures for claiming the surplus, only to be denied it, then she could immediately bring a takings claim under § 1983. That is all that Knick guarantees." Howard vs. Macomb County, MI, 25a0070p-06.pdf<https://www.opn.ca6.uscourts.gov/opinions.pdf/25a0070p-06.pdf> FWIW: This case may rear its ugly head as a cert petition to the SCOTUS and may be the type of case the libertarian and a couple of conservatives would enjoy. 9th Circuit - RLUIPA - Matters of Law Church buys agriculturally zoned land and applies for a special use exception to build a church (ever heard that before). Special Exception is denied and church sues. Case goes to trial. Court instructs jury on the question of government imposing a "substantial burden" on a person's or religious institution's "religious exercise" unless the burden is the least restrictive means of furthering a compelling government interest and ask the jury to decide if such were the case when the special exception was denied. The jury sides with the county and concludes it did not impose a substantial burden on the church's religious exercise. On appeal, a really upset church claims the lower court should not have given the instruction as it did. A minor skirmish ensued over whether that argument was waived and whether the Defendants waived making the waiver argument. But as the sun came up over Maui the panel concluded that the issue was really a matter of law, the judge should have decided the question but since the jury decided it the way the judge should have decided it, no harm no foul and the lower court judgement was affirmed. So, surf's up - go hang ten. Spirit of Aloha Temple vs. County of Maui, 23-3633.pdf<https://cdn.ca9.uscourts.gov/datastore/opinions/2025/03/28/23-3633.pdf> Charles W. Thompson, Jr. Of Counsel P: (202) 466-5424 x7110 M: (240) 876-6790 D: (202) 742-1016 [facebook icon]<https://www.facebook.com/InternationalMunicipalLawyersAssociation/>[twitter icon]<https://twitter.com/imlalegal>[linkedin icon]<https://www.linkedin.com/company/international-municipal-lawyers-association-inc./> [logo]<https://imla.org/> 51 Monroe St. Suite 404 Rockville, MD, 20850 www.imla.org<http://www.imla.org/>

Martha Thompson

Wed, Apr 2, 2025 10:01 PM

Thanks Chuck. Informative AND entertaining as always

[cid:image005.png@01DBA3F9.4D66F9A0]

Martha Thompson
Executive Legal Counsel
Gaston County Attorney’s Office

128 West Main Ave.
P.O. Box 1578
Gastonia, NC 28052

Office: (704) 866-3227
Cell: (704) 470-7439
Martha.Thompson@GastonGov.com

Martindale-Hubbell AV Preeminent* Peer/Judicial Rating
*the highest possible rating for 20+ years

From: Chuck Thompson via Counties counties@lists.imla.org
Sent: Tuesday, April 1, 2025 11:14 AM
To: Federal Law List Serve federal@lists.imla.org; cityattorneys@lists.imla.org; counties@lists.imla.org; Landuse@lists.imla.org; employlaw@lists.imla.org
Cc: Edward Maggio emaggio@imla.org; Erich Eiselt eeiselt@imla.org
Subject: [EXTERNAL] [Counties] Cases of Interest

Michigan – Supreme Court – Taxes – Statutory Interpretation – Due Process
For those of you unacquainted with the Michigan Supreme Court (and I’m one of you), the court issues opinions and like the SCOTUS includes a headnote of its opinion. Unlike the SCOTUS the drafters of the headnote in Michigan are not familiar with the common writing tool often called “a paragraph” nor do the drafters consider brevity to be the soul of wit. Thus, the headnote is probably denser than the opinion itself. Having waded through the headnote and leaving aside Michigan specific substantive issues, that leaves us with due process. The case involves a company that sought a tax exemption. The statute provides the method for applying for and appealing decisions regarding these exemptions. The statute specifies what notice the taxpayer should receive. The administrative tribunal charged with hearing these appeals concluded it lacked jurisdiction to adjudicate the issues because the appeal was not timely filed. Michigan’s intermediate court reversed concluding the notice given to the taxpayer was inadequate despite being complicit with the statute as the intermediate court in the “hand holding” mode felt the notice could have been more clear and explicit. The Supreme Court felt otherwise concluding due process was not violated as the taxpayer had actual notice of the filing requirements and that the notices given; albeit bare, were compliant with the law. (Apologies to all if my ability to synopsize what occurred missed something).
SIXARP, LLC v TOWNSHIP OF BYRON, MSC 166190 SIXARP LLC V TOWNSHIP OF BYRON Opinion on Application - Reverse CoA 3/26/2025https://urldefense.com/v3/__https:/www.courts.michigan.gov/siteassets/case-documents/uploads/OPINIONS/FINAL/SCT/166190_43_01.pdf__;!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wloZ59Kr1p$

7th Circuit – Reverse Discrimination – Right to Sue - Improper Defendant
It’s quite astounding to see folks who have licensed attorneys sue entities of state or local government that cannot sue or be sued. Such was the case here where a reverse discrimination claim sought to hold accountable the Marion County Prosecutor’s Office for an equal protection violation. But, was the “office” a “person” under the state law? No, the office was not an independent entity under state law that could be sued under state law nor could it be considered a “person” under the Civil Rights Act. Another obstacle the Plaintiff could not overcome in her Title ViI claim stood the 90 day requirement to file suit after receiving a right to sue letter. She received the letter via email but did not open it until the next day. She filed suit 91 days after receipt and 90 days after opening it. Too late!
Kiinder vs. Marion County Prosecutor’s Office, processWebInputExternal.plhttps://urldefense.com/v3/__https:/media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2025*D03-26*C:24-1952:J:Brennan:aut:T:fnOp:N:3351133:S:0__;Ly8!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wloaNHuESM$

Be aware: If someone sues your police department or another department of your local government determine if the entity is one that can be sued; i.e., is it a “person”, can it be sued by virtue of a statutory provision under state or local law. Consider raising the issue after limitations have passed.

6th Circuit – Taxes – Fifth Amendment – Tax Sales
Michigan has dealt with issues arising from its tax sale process for several years. After learning that its process, including forfeiting surplus proceeds from the sale to the government, failed Constitutional muster, the state amended its laws to bring them into compliance. The Plaintiff in this case sought to recover surplus proceeds from a sale, but did not follow the procedures established under the new laws. Can she recover – no. The Plaintiff failed to act as required by the law to seek to recover the surplus proceeds in a timely manner. Recognizing the problem, the Plaintiff raised the issue that under Knick v. Township of Scott, 588 U.S. 180 (2019), she need not file anything to protect her property against expropriation by the government. The Court replied:” But unlike the state laws at issue in Knick, Michigan’s procedures for collecting the surplus do not compensate the property owner for a taking. They prevent a taking from happening in the first place. A county that allows property owners to obtain any surplus after a foreclosure and keeps the residual only if the owners do not seek it does not commit a taking. See Nelson, 352 U.S. at 110; see also Tyler, 598 U.S. at 644. Had Howard followed the Act’s procedures for claiming the surplus, only to be denied it, then she could immediately bring a takings claim under § 1983. That is all that Knick guarantees.”
Howard vs. Macomb County, MI, 25a0070p-06.pdfhttps://urldefense.com/v3/__https:/www.opn.ca6.uscourts.gov/opinions.pdf/25a0070p-06.pdf__;!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wlodbIiKX6$

FWIW: This case may rear its ugly head as a cert petition to the SCOTUS and may be the type of case the libertarian and a couple of conservatives would enjoy.

9th Circuit – RLUIPA – Matters of Law
Church buys agriculturally zoned land and applies for a special use exception to build a church (ever heard that before). Special Exception is denied and church sues. Case goes to trial. Court instructs jury on the question of government imposing a “substantial burden” on a person’s or religious institution’s “religious exercise” unless the burden is the least restrictive means of furthering a compelling government interest and ask the jury to decide if such were the case when the special exception was denied. The jury sides with the county and concludes it did not impose a substantial burden on the church’s religious exercise. On appeal, a really upset church claims the lower court should not have given the instruction as it did. A minor skirmish ensued over whether that argument was waived and whether the Defendants waived making the waiver argument. But as the sun came up over Maui the panel concluded that the issue was really a matter of law, the judge should have decided the question but since the jury decided it the way the judge should have decided it, no harm no foul and the lower court judgement was affirmed. So, surf’s up – go hang ten.
Spirit of Aloha Temple vs. County of Maui, 23-3633.pdfhttps://urldefense.com/v3/__https:/cdn.ca9.uscourts.gov/datastore/opinions/2025/03/28/23-3633.pdf__;!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wloRnr3vRw$

Charles W. Thompson, Jr.
Of Counsel
P: (202) 466-5424 x7110
M: (240) 876-6790
D: (202) 742-1016
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Thanks Chuck. Informative AND entertaining as always [cid:image005.png@01DBA3F9.4D66F9A0] Martha Thompson Executive Legal Counsel Gaston County Attorney’s Office 128 West Main Ave. P.O. Box 1578 Gastonia, NC 28052 Office: (704) 866-3227 Cell: (704) 470-7439 Martha.Thompson@GastonGov.com Martindale-Hubbell AV Preeminent* Peer/Judicial Rating *the highest possible rating for 20+ years From: Chuck Thompson via Counties <counties@lists.imla.org> Sent: Tuesday, April 1, 2025 11:14 AM To: Federal Law List Serve <federal@lists.imla.org>; cityattorneys@lists.imla.org; counties@lists.imla.org; Landuse@lists.imla.org; employlaw@lists.imla.org Cc: Edward Maggio <emaggio@imla.org>; Erich Eiselt <eeiselt@imla.org> Subject: [EXTERNAL] [Counties] Cases of Interest Michigan – Supreme Court – Taxes – Statutory Interpretation – Due Process For those of you unacquainted with the Michigan Supreme Court (and I’m one of you), the court issues opinions and like the SCOTUS includes Michigan – Supreme Court – Taxes – Statutory Interpretation – Due Process For those of you unacquainted with the Michigan Supreme Court (and I’m one of you), the court issues opinions and like the SCOTUS includes a headnote of its opinion. Unlike the SCOTUS the drafters of the headnote in Michigan are not familiar with the common writing tool often called “a paragraph” nor do the drafters consider brevity to be the soul of wit. Thus, the headnote is probably denser than the opinion itself. Having waded through the headnote and leaving aside Michigan specific substantive issues, that leaves us with due process. The case involves a company that sought a tax exemption. The statute provides the method for applying for and appealing decisions regarding these exemptions. The statute specifies what notice the taxpayer should receive. The administrative tribunal charged with hearing these appeals concluded it lacked jurisdiction to adjudicate the issues because the appeal was not timely filed. Michigan’s intermediate court reversed concluding the notice given to the taxpayer was inadequate despite being complicit with the statute as the intermediate court in the “hand holding” mode felt the notice could have been more clear and explicit. The Supreme Court felt otherwise concluding due process was not violated as the taxpayer had actual notice of the filing requirements and that the notices given; albeit bare, were compliant with the law. (Apologies to all if my ability to synopsize what occurred missed something). SIXARP, LLC v TOWNSHIP OF BYRON, MSC 166190 SIXARP LLC V TOWNSHIP OF BYRON Opinion on Application - Reverse CoA 3/26/2025<https://urldefense.com/v3/__https:/www.courts.michigan.gov/siteassets/case-documents/uploads/OPINIONS/FINAL/SCT/166190_43_01.pdf__;!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wloZ59Kr1p$> 7th Circuit – Reverse Discrimination – Right to Sue - Improper Defendant It’s quite astounding to see folks who have licensed attorneys sue entities of state or local government that cannot sue or be sued. Such was the case here where a reverse discrimination claim sought to hold accountable the Marion County Prosecutor’s Office for an equal protection violation. But, was the “office” a “person” under the state law? No, the office was not an independent entity under state law that could be sued under state law nor could it be considered a “person” under the Civil Rights Act. Another obstacle the Plaintiff could not overcome in her Title ViI claim stood the 90 day requirement to file suit after receiving a right to sue letter. She received the letter via email but did not open it until the next day. She filed suit 91 days after receipt and 90 days after opening it. Too late! Kiinder vs. Marion County Prosecutor’s Office, processWebInputExternal.pl<https://urldefense.com/v3/__https:/media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2025*D03-26*C:24-1952:J:Brennan:aut:T:fnOp:N:3351133:S:0__;Ly8!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wloaNHuESM$> Be aware: If someone sues your police department or another department of your local government determine if the entity is one that can be sued; i.e., is it a “person”, can it be sued by virtue of a statutory provision under state or local law. Consider raising the issue after limitations have passed. 6th Circuit – Taxes – Fifth Amendment – Tax Sales Michigan has dealt with issues arising from its tax sale process for several years. After learning that its process, including forfeiting surplus proceeds from the sale to the government, failed Constitutional muster, the state amended its laws to bring them into compliance. The Plaintiff in this case sought to recover surplus proceeds from a sale, but did not follow the procedures established under the new laws. Can she recover – no. The Plaintiff failed to act as required by the law to seek to recover the surplus proceeds in a timely manner. Recognizing the problem, the Plaintiff raised the issue that under Knick v. Township of Scott, 588 U.S. 180 (2019), she need not file anything to protect her property against expropriation by the government. The Court replied:” But unlike the state laws at issue in Knick, Michigan’s procedures for collecting the surplus do not compensate the property owner for a taking. They prevent a taking from happening in the first place. A county that allows property owners to obtain any surplus after a foreclosure and keeps the residual only if the owners do not seek it does not commit a taking. See Nelson, 352 U.S. at 110; see also Tyler, 598 U.S. at 644. Had Howard followed the Act’s procedures for claiming the surplus, only to be denied it, then she could immediately bring a takings claim under § 1983. That is all that Knick guarantees.” Howard vs. Macomb County, MI, 25a0070p-06.pdf<https://urldefense.com/v3/__https:/www.opn.ca6.uscourts.gov/opinions.pdf/25a0070p-06.pdf__;!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wlodbIiKX6$> FWIW: This case may rear its ugly head as a cert petition to the SCOTUS and may be the type of case the libertarian and a couple of conservatives would enjoy. 9th Circuit – RLUIPA – Matters of Law Church buys agriculturally zoned land and applies for a special use exception to build a church (ever heard that before). Special Exception is denied and church sues. Case goes to trial. Court instructs jury on the question of government imposing a “substantial burden” on a person’s or religious institution’s “religious exercise” unless the burden is the least restrictive means of furthering a compelling government interest and ask the jury to decide if such were the case when the special exception was denied. The jury sides with the county and concludes it did not impose a substantial burden on the church’s religious exercise. On appeal, a really upset church claims the lower court should not have given the instruction as it did. A minor skirmish ensued over whether that argument was waived and whether the Defendants waived making the waiver argument. But as the sun came up over Maui the panel concluded that the issue was really a matter of law, the judge should have decided the question but since the jury decided it the way the judge should have decided it, no harm no foul and the lower court judgement was affirmed. So, surf’s up – go hang ten. Spirit of Aloha Temple vs. County of Maui, 23-3633.pdf<https://urldefense.com/v3/__https:/cdn.ca9.uscourts.gov/datastore/opinions/2025/03/28/23-3633.pdf__;!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wloRnr3vRw$> Charles W. Thompson, Jr. Of Counsel P: (202) 466-5424 x7110 M: (240) 876-6790 D: (202) 742-1016 [facebook icon]<https://urldefense.com/v3/__https:/www.facebook.com/InternationalMunicipalLawyersAssociation/__;!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wloenJDzZ1$>[twitter icon]<https://urldefense.com/v3/__https:/twitter.com/imlalegal__;!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wloSkjvUD5$>[linkedin icon]<https://urldefense.com/v3/__https:/www.linkedin.com/company/international-municipal-lawyers-association-inc./__;!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wloSUPCt6N$> [logo]<https://urldefense.com/v3/__https:/imla.org/__;!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wloWtygH5i$> 51 Monroe St. Suite 404 Rockville, MD, 20850 www.imla.org<https://urldefense.com/v3/__http:/www.imla.org/__;!!KlcEyFNMN_PGWg!CeoTkFY0Zg3oPxqsn8k3TfntBEry0sD6rn046a4IucCPD1kRP4oZGKnpS1krawM5j8F2CHuznF00kQE4I_wloWQyLQtN$> ____________________________________________________________________________________________________________________________________________ This message may contain confidential information and is intended only for the individual named. 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