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Zoning Bulletin November 25, 2015 1 Volume 9 1 Issue 22 <br />See also: Urban Housing of America, Inc. v. City of Shreveport, 26 So. <br />3d 226 (La. Ct. App. 2d Cir. 2009), writ denied, 34 So. 3d 269 (La. 2010). <br />See also: WRW Properties, LLC v. City of Shreveport, 112 So. 3d 279 <br />(La. Ct. App. 2d Cir. 2013). <br />Enforcement/Governmental <br />Immunity—After court fines <br />landowner for each day of zoning <br />violation, landowner argues <br />jurisdictional limit on fines in <br />district court <br />Town contends statutory amendment specifying <br />each day's violation constituted a separate <br />offense, applied retroactively, allowing fine to <br />not conflict with jurisdictional limit <br />Citation: Town of Bartlett v. Furlong, 2015 WL 5559856 (N.H. 2015) <br />NEW HAMPSHIRE (09/22/15)—This case addressed the issue of <br />whether a statutory amendment to a zoning fines and penalties statute, <br />which clarified that each day of a violation of a land use ordinance consti- <br />tuted a separate offense, and thereby eliminated any possible conflict with a <br />district court's jurisdictional limit of $25,000, applied retroactively, thus <br />allowing the court to impose a fine greater than $25,000 for a property <br />owner's ongoing ordinance violation. <br />The Background/Facts: Edward C. Furlong, III ("Furlong") owned <br />property in the Town of Bartlett (the "Town"). Furlong began renovation <br />work on the property in the fall of 2008. In October 2008, the Town's Board <br />of Selectman (the "Board") notified Furlong that he needed a building <br />permit for the renovations, and issued to him a cease and desist notice. The <br />cease and desist notice informed Furlong that he violated the Town's zon- <br />ing ordinance. Furlong thereafter submitted two incomplete applications <br />for a building permit. Despite the Town informing him that the applications <br />were incomplete, Furlong did not submit further information. Furlong <br />instead completed the renovation work without a permit. <br />In December 2008, the Board filed a land use citation complaint in the <br />district court against Furlong. The complaint advised Furlong that he could <br />be fined $275 for the first day and $550 for every day thereafter that the <br />violation continued. <br />Ultimately, the trial court entered judgment in favor of the Town and <br />© 2015 Thomson Reuters 7 <br />