PDF_1_Entire_Tribunal_Petition_and_Attachments_A-F.pdf

Cletis Kendrick Petitioner Vs. City Of Detroit Respondent · 26-002687-TT

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v 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

DIRECTOR 

LANSING 

_____________________________, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

MTT Docket No. 

_____________________________, 

Respondent(s) 

ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

1.

Property Parcel No: ________________________________________________

2.

The property identified above is ___real ___personal.

3.

The special assessment levied is for ___________________________________

4.

The taxing authority levying the special assessment is

5.

The action that prompted this appeal is _________________________________

6.

The hearing held to confirm the special assessment was held on

7.

Petitioner ______ (did/did not) protest the special assessment at this hearing. If a

protest was not made, list the separate and specific facts upon which Petitioner

relies to invoke the Tribunal’s authority over the special assessment at issue

(attach additional page if necessary):

8.

The special assessment is to be levied for ________________years.

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 

CLETIS KENDRICK

CITY OF DETROIT

X

Sherwood Forest SAD SMS/SWF Charge: 

Snow Removal, Mosquito Abatement, Security Patrol.

02004962.001

City of Detroit

Disputed — Detroit appears to rely on November 21, 2023.

did not

Petitioner did not protest at a lawful Sherwood Forest roll-confirmation hearing because Detroit 

has not produced evidence that such a hearing was lawfully noticed, conducted, or supported by

a Clerk-filed tentative assessment roll and confirmed Sherwood Forest special assessment roll.

Petitioner relies on the attached Petition, Attachments A-F, and Exhibits 1-15 to invoke the

Tribunal's authority over the current 2026 special assessment charge.

7 (purported; disputed)

The 2026 Detroit Summer Property Tax Bill imposing 

the $300 Sherwood Forest SMS/SWF special assessment charge against Parcel No. 02004962.001.

MTT Docket No. 

Page 2 of 2 

9. 

The total amount levied against the subject parcel is $300.00 

10. 

Petitioner contends that the total amount levied should be $0.00 

11. 

The amount in dispute is $300.00 plus derivative refund and correction relief. 

12. 

Petitioner requests the following relief (attach additional page if necessary): 

See attached "Supplement to ET Special Assessment Petition — Relief Requested.” 

13. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

See attached "Supplement to ET Special Assessment Petition — Separate and Specific Facts." 

Signature of ORE Ae 

ebe 

ntative or, if none, Petitioner: 

Printed Name of Petitioner's Authorized Representative or, if none, Petitioner: 

Cletis Kendrick 

Email Address: cbkendrick@att.net 

Mailing 

Add 

; 

ailing 

AAAI®SS: 19130 Parkside 

Detroit, MI 48221 

Telephone Number: 

(313) 244-7249 

Date: 

67/14/2024

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL DIVISION 

CLETIS KENDRICK, 

Petitioner, 

v. 

CITY OF DETROIT, 

Respondent. 

MTT Docket No. __________________ 

SUPPLEMENT TO ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

LINE 12 — RELIEF REQUESTED 

12. Petitioner requests the following relief:

Petitioner requests cancellation, removal, refund by direct payment, and tax-record correction of the 

2026 SMS/SWF $300 special assessment charge imposed against Parcel No. 02004962.001. The 2026 

Detroit property tax bill, including the challenged SMS/SWF charge, has been paid in full. If the Tribunal 

determines that Detroit lacked lawful authority to impose the 2026 SMS/SWF charge, Petitioner requests 

refund by direct payment to Petitioner, with applicable interest, and correction of the City’s tax and 

special assessment records. Petitioner does not request a credit against future taxes, future special 

assessments, other tax liabilities, or later City charges unless Petitioner expressly agrees in writing. 

Petitioner further requests that Detroit be prohibited from imposing any future SMS/SWF charge against 

Petitioner’s parcel under the claimed 2023 Sherwood Forest SAD renewal unless Detroit proves a lawful 

authority chain for that renewal. 

If the Tribunal determines that Detroit’s claimed 2023 Sherwood Forest SAD renewal was unlawful, void, 

unsupported, or not lawfully confirmed, Petitioner also requests derivative refund, direct-payment relief, 

and record-correction relief, to the extent within the Tribunal’s authority in this docket, for all 

SMS/SWF amounts imposed and paid under that same claimed renewal, including direct refund of the paid 

2024 SMS/SWF charges totaling $300, direct refund of the paid 2025 SMS/SWF charge of $300, direct 

refund of the paid 2026 SMS/SWF charge of $300, applicable interest, and correction of any City, County, 

tax, delinquency, penalty, interest, administrative-charge, lien, collection, forfeiture, or special assessment 

record attributable to those charges.

Petitioner specifically requests monetary refund by direct payment to Petitioner, not a credit against future 

property taxes, future special assessments, other tax liabilities, or later City charges, unless Petitioner 

expressly agrees in writing.

In the alternative, Petitioner does not concede that a separate amendment, supplemental petition, separate 

docket, City administrative correction, County correction process, or other procedure is required for the 

2024 or 2025 SMS/SWF refund and record-correction relief. Petitioner’s primary position is that the 

Tribunal may grant that derivative relief in this docket because the 2024, 2025, and 2026 SMS/SWF 

charges all arise from the same claimed 2023 Sherwood Forest SAD renewal. However, if the Tribunal 

determines that any additional procedure is required to process refund, direct-payment relief, Wayne County 

Treasurer record correction, delinquency-record correction, or correction of the 2024 or 2025 SMS/SWF 

charges, Petitioner requests that any final order expressly preserve Petitioner’s right to pursue those 

derivative remedies based on the Tribunal’s determination concerning Detroit’s claimed 2023 Sherwood 

Forest SAD renewal authority. 

Line 12 Relief Supplement — Page 1 of 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL DIVISION 

CLETIS KENDRICK, 

Petitioner, 

v. 

CITY OF DETROIT, 

Respondent. 

MTT Docket No. __________________ 

SUPPLEMENT TO ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

LINE 13 — SEPARATE AND SPECIFIC FACTS SUPPORTING RELIEF 

13. List the separate and specific facts upon which Petitioner relies to support the relief requested:

The 2024, 2025, and 2026 SMS/SWF charges all arise from Detroit’s claimed 2023 Sherwood Forest 

SAD renewal. Petitioner’s position is that the current 2026 SMS/SWF charge is derivative of that 

claimed 2023 renewal. If the claimed 2023 renewal lacked lawful petition support, 51% land-area 

verification, DNIO certification, public notice, mailed notice, hearing authority, roll confirmation, Clerk 

endorsement, Treasury transmittal, billing authority, annual accounting, redetermination, or tax parcel 

share calculation, then the charges imposed under that same claimed renewal are likewise unsupported. 

The 2024 Detroit property tax bill, including the SMS/SWF charge, was paid in full. The 2025 Detroit 

property tax bill, including the SMS/SWF charge, was paid in full through the Wayne County Treasurer 

after the bill entered the delinquent tax process. The 2026 Detroit property tax bill, including the 

SMS/SWF charge, was paid in full. 

Petitioner did not originally pay the 2025 bill in full because the 2025 SMS/SWF charge became 

disputed after Petitioner discovered facts and records indicating that Detroit’s claimed 2023 Sherwood 

Forest SAD renewal may lack lawful authority. Detroit does not permit Petitioner to pay the Detroit 

property tax bill while excluding only the SMS/SWF charge. Payment of the 2025 delinquent balance 

through Wayne County was therefore a protective payment to prevent additional delinquency, interest, 

penalty, lien, forfeiture, collection, or property-loss consequences, not a waiver of Petitioner’s challenge 

to the SMS/SWF charge. 

Payment of the 2024, 2025, or 2026 property tax bill, including any SMS/SWF amount, was not consent 

to the SMS/SWF charge, waiver of objection, agreement to the Sherwood Forest SAD renewal, or 

admission that Detroit had lawful authority. The SMS/SWF charge was imposed as a compulsory 

property-tax-bill line item that could not be separately excluded from payment without exposing the 

parcel to tax-delinquency, interest, penalty, lien, forfeiture, or collection consequences. 

Detroit’s claimed 2023 Sherwood Forest SAD renewal is disputed because Detroit has not produced the 

complete authority chain required to support the current charge. The missing or disputed records 

include, but are not limited to, a City-certified 51% land-area petition calculation, Administering 

Department petition-validity report, lawful DNIO certification, Clerk-filed tentative assessment roll, 

Sherwood Forest-specific hearing-setting resolution, lawful mailed notice, proof of mailing, public-

Line 13 Facts Supplement — Page 1 of 2

examination record, confirmed special assessment roll, Clerk endorsement, delivery or transmittal to 

Treasury, Treasury billing authority, annual accounting, redetermination, and tax parcel share 

calculation. 

Petitioner relies on the attached Petition, Attachments A–F and Exhibits 1–15 to show that Detroit’s 

claimed 2023 Sherwood Forest SAD renewal was not supported by the required lawful authority chain. 

The 2026 SMS/SWF charge is the current charge before the Tribunal, but the 2024, 2025, and 2026 

charges were imposed under the same claimed renewal. Therefore, if the Tribunal determines that the 

claimed 2023 renewal was unlawful, void, unsupported, or not lawfully confirmed, Petitioner seeks 

direct refund and record correction for the paid SMS/SWF charges imposed under that same defective 

claimed renewal, to the extent within the Tribunal’s authority in this docket. 

Petitioner specifically seeks direct refund by payment to Petitioner, not credit against future taxes, 

future special assessments, other tax liabilities, or later City charges, unless Petitioner expressly agrees 

in writing. Petitioner also seeks correction of any City, County, delinquency, penalty, interest, 

administrative-charge, lien, collection, forfeiture, or tax-record consequence attributable to any 

SMS/SWF charge imposed under the defective claimed renewal. 

Petitioner does not concede that a separate amendment, supplemental petition, separate docket, City 

administrative correction, County correction process, or other procedure is required for the 2024 or 2025 

SMS/SWF refund and record-correction relief. Petitioner’s primary position is that the Tribunal may 

grant that derivative relief in this docket because the 2024, 2025, and 2026 SMS/SWF charges all arise 

from the same claimed 2023 Sherwood Forest SAD renewal. If the Tribunal determines that any 

additional procedure is required to process refund, direct-payment relief, Wayne County Treasurer 

record correction, delinquency-record correction, or correction of the 2024 or 2025 SMS/SWF charges, 

Petitioner requests that any final order expressly preserve Petitioner’s right to pursue those derivative 

remedies based on the Tribunal’s determination concerning Detroit’s claimed 2023 Sherwood Forest 

SAD renewal authority. 

Line 13 Facts Supplement — Page 2 of 2

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL DIVISION 

CLETIS KENDRICK, 

Petitioner, 

v. 

MTT Docket No. __________________ 

CITY OF DETROIT, 

Respondent. 

ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

Petitioner, Cletis Kendrick, files this Entire Tribunal Special Assessment Petition challenging the City 

of Detroit’s lawful authority to impose and continue collecting the current 2026 SMS/SWF special 

assessment charge against Petitioner’s parcel under Detroit’s claimed 2023 renewal of the Sherwood 

Forest Special Assessment District. 

1. Subject Property

The subject property is real property located at: 

19130 Parkside 

Detroit, Michigan 48221 

Parcel No. 02004962.001 

Certain City of Detroit parcel, tax, or assessment records may identify Petitioner as “Cleatis Kendrick.” 

Petitioner files this appeal under his correct legal name, Cletis Kendrick. Any City record using “Cleatis 

Kendrick” in connection with the subject parcel should be understood as referring to the same property, 

same ownership chain, and same parcel at issue in this appeal. 

2. Respondent

Respondent is the City of Detroit, the taxing authority that imposed the challenged 2026 SMS/SWF 

special assessment charge. 

3. Assessment Challenged

Petitioner challenges the 2026 SMS/SWF special assessment charge imposed against Parcel No. 

02004962.001 on the City of Detroit’s 2026 Summer Property Tax Bill. 

The charge is imposed under Detroit’s claimed 2023 renewal of the Sherwood Forest Special Assessment 

District for snow removal, mosquito abatement, and security services. 

The 2026 charge is derivative of Detroit’s claimed 2023 Sherwood Forest SAD renewal. Detroit must 

therefore prove the lawful 2023 renewal authority chain on which the current 2026 charge depends. 

4. Amount in Dispute

The amount of the 2026 SMS/SWF charge imposed against Petitioner’s parcel is: 

$300.00 

Petitioner contends that the amount lawfully levied should be: 

$0.00 

Entire Tribunal Petition — Page 1 of 4

The amount in dispute is $300.00, plus any penalty, interest, collection charge, lien consequence, 

forfeiture consequence, future billing consequence, or continuing assessment consequence arising from 

the challenged 2026 SMS/SWF charge. 

5. Nature of Appeal

This is a special-assessment authority challenge. 

Petitioner does not challenge the taxable value, assessed value, property classification, or principal-

residence exemption status of the property. 

Petitioner challenges whether Detroit had lawful authority to impose and continue collecting the current 

2026 SMS/SWF charge when Detroit has not produced the Sherwood Forest authority-chain records 

required by MCL 117.5i and Detroit City Code Division 8. 

6. Summary of Challenge

Petitioner contends that Detroit has not produced the records necessary to establish lawful authority for 

the current 2026 SMS/SWF charge, including the Sherwood Forest petition summary, City-certified 

51% land-area verification, Administering Department report, tentative assessment roll, Sherwood 

Forest-specific resolution, final resolution, confirmed special assessment roll, Clerk endorsement, 

delivery or transmittal to Treasury, Treasury billing-authority record, annual accounting / 

redetermination record, and tax parcel share calculation. 

Petitioner further contends that the controlling petition requirement is support from record owners 

representing not less than 51% of the land area within the actual Sherwood Forest SAD boundaries, 

measured by square footage, and that Petitioner’s reconstructed land-area verification shows the 

Sherwood Forest renewal petition did not satisfy that threshold. 

A later hearing, combined resolution, waiver vote, billing list, assessment extract, Treasury processing record, 

or tax-bill line item cannot cure the absence of lawful authority at the original statutory gateway stage. 

7. Protest Position

Petitioner disputes that any protest bar applies. 

Petitioner did not protest at a lawful Sherwood Forest roll-confirmation hearing because Detroit has not 

produced evidence that such a hearing was lawfully noticed, conducted, or supported by a Clerk-filed 

tentative assessment roll and confirmed Sherwood Forest special assessment roll. 

Petitioner has never received mailed notice of a lawful Sherwood Forest roll-confirmation hearing. 

Detroit has not produced proof of mailed notice to Petitioner, a protest warning tied to a lawful roll-

confirmation hearing, a Clerk-filed roll available for public examination, a confirmed Sherwood Forest 

special assessment roll, Clerk endorsement, or delivery-to-Treasury record. 

Without those predicate records, Detroit cannot establish that Petitioner received a meaningful 

opportunity to protest or that any protest bar was triggered. 

8. Attachments and Exhibits

Petitioner relies on the attached documents in support of this appeal, including: 

Attachment A — Petitioner’s Expanded Entire Tribunal Special Assessment Petition 

Attachment B — Petitioner’s Preliminary Statement and Filing Theory 

Attachment C — Jurisdiction and Tribunal Authority 

Entire Tribunal Petition — Page 2 of 4

Attachment D — Statement of Issues Presented 

Attachment E — Petition Land-Area Verification Summary 

Attachment F — Core Exhibit Index 

Exhibits 1–15 

Petitioner reserves the right to supplement the record with additional City records, FOIA productions, tax 

records, petition records, land-area verification materials, publication records, notice records, hearing 

records, assessment-roll records, Treasury records, or authority-chain records produced after filing. 

9. Requested Relief

Petitioner requests that the Tribunal: 

1. Cancel or remove the 2026 SMS/SWF charge from Parcel No. 02004962.001;

2. Determine that Detroit has not established lawful authority to impose the 2026 SMS/SWF charge 

unless Detroit produces the complete Sherwood Forest authority chain required by MCL 117.5i and 

Detroit City Code Division 8;

3. Correct Petitioner’s tax and special assessment records to remove the challenged 2026 SMS/SWF 

charge;

4. Order refund by direct payment to Petitioner, not credit, unless Petitioner expressly agrees in 

writing, of any amount paid toward the challenged 2026 SMS/SWF charge, with applicable interest;

5. Require Detroit, if it contests this appeal, to identify and produce the official records supporting 

petition sufficiency, land-area verification, DNIO certification, public notice, mailed notice, public-

examination availability, roll confirmation, Clerk endorsement, Treasury transmittal, billing 

authority, annual accounting, redetermination, and tax parcel share calculation;

6. Prevent continued collection, enforcement, penalty, interest, lien, forfeiture, or future billing 

consequences arising from the challenged 2026 SMS/SWF charge unless Detroit establishes lawful 

authority; and

7. Grant any further relief the Tribunal determines is just and proper.

10. Conclusion

Detroit may not rely on a tax-bill line item alone to establish lawful authority for the current 2026 

SMS/SWF charge. 

The 2026 SMS/SWF charge is derivative of Detroit’s claimed 2023 Sherwood Forest SAD renewal. 

That claimed 2023 renewal has not yet been lawfully proven by a produced Sherwood Forest authority 

chain showing petition sufficiency, 51% land-area verification, DNIO certification, public notice, 

mailed notice, public-examination availability, roll confirmation, Clerk endorsement, Treasury 

transmittal, billing authority, annual accounting, redetermination, and tax parcel share calculation. 

Detroit’s nonproduction of the required lawful-authority chain also defeats any claim that Petitioner 

had a meaningful and reasonable opportunity to protest. A protest bar cannot arise from an unproven 

or defectively noticed process unsupported by the required Sherwood Forest-specific resolution, Clerk-

filed tentative assessment roll, lawful roll-confirmation hearing notice, confirmed special assessment 

roll, Clerk endorsement, and delivery-to-Treasury record. 

Entire Tribunal Petition — Page 3 of 4

Petitioner asks the Tribunal to determine whether Detroit can establish the legal-authority chain required 

to impose and continue collecting the challenged 2026 SMS/SWF charge. If Detroit cannot establish 

that authority, Petitioner requests cancellation, correction, refund by direct payment to Petitioner, not 

credit unless Petitioner expressly agrees in writing, and relief from further collection or enforcement. 

Respectfully submitted, 

4 

» 

Cletis Kendrick, Petitioner 

19130 Parkside 

Detroit, Michigan 48221 

Phone: (313) 244-7249 

Email: cbkendrick@att.net 

Date: 

07/7 EL 

Entire Tribunal Petition — Page 4 of 4

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL DIVISION 

CLETIS KENDRICK, 

Petitioner, 

v. MTT Docket No. __________

CITY OF DETROIT, 

Respondent. 

ATTACHMENT A — EXPANDED ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

Petitioner, Cletis Kendrick, files this Entire Tribunal Special Assessment Petition challenging the City 

of Detroit’s lawful authority to impose the current 2026 Sherwood Forest SMS/SWF special 

assessment charge against Petitioner’s parcel. 

1. Property Parcel No.: 02004962.001

2. The property identified above is real property.

3. The special assessment challenged in this appeal is the City of Detroit’s 2026 SMS/SWF charge,

imposed under Detroit’s claimed 2023 renewal of the Sherwood Forest Special Assessment

District for snow removal, mosquito abatement, and security services.

4. The taxing authority levying the special assessment is the City of Detroit.

5. The action that prompted this appeal is Detroit’s 2026 property-tax billing of the Sherwood

Forest SMS/SWF special assessment against Petitioner’s parcel.

6. The 2026 SMS/SWF charge is derivative of Detroit’s claimed 2023 Sherwood Forest SAD

renewal. Detroit must therefore prove the lawful 2023 renewal authority chain on which the

current 2026 charge depends.

7. The hearing allegedly held to confirm the Sherwood Forest special assessment roll is disputed.

Detroit has not produced a Sherwood Forest-specific roll-confirmation hearing notice,

confirmed special assessment roll, Clerk endorsement, or delivery-to-Treasury record.

Detroit’s November 21, 2023, combined approval is the City’s purported final approval event,

but Petitioner disputes that it constituted lawful confirmation of a Sherwood Forest special

assessment roll under MCL 117.5i and Detroit City Code Division 8.

8. Petitioner could not protest at a lawful Sherwood Forest roll-confirmation hearing because

Detroit has not produced evidence that such a hearing was lawfully noticed, conducted, or

supported by a Clerk-filed tentative assessment roll and confirmed Sherwood Forest special

assessment roll. Petitioner therefore contests any claim that an unproduced or defectively noticed

confirmation process can bar review of the current 2026 SMS/SWF charge.

9. The special assessment is purportedly part of a renewed seven-year Sherwood Forest SAD term.

Petitioner disputes the legality of that purported renewed term because Detroit has not produced

the confirmed Sherwood Forest special assessment roll from which any lawful renewed term

could commence.

Attachment A — Page 1 of 2

10. The total amount levied against the subject parcel for the 2026 SMS/SWF charge is $300.00. 

11. Petitioner contends that the total amount lawfully levied should be $0.00. 

12. The amount in dispute is $300.00, plus any penalty, interest, collection charge, lien consequence, 

13. 

14. 

forfeiture consequence, or continuing assessment arising from the challenged 2026 SMS/SWF 

charge. 

Petitioner requests that the Tribunal cancel the 2026 SMS/SWF special assessment charge against 

Petitioner’s parcel, determine that Detroit has not established lawful authority to impose the 

charge unless it produces the complete Sherwood Forest Division 8 authority chain, correct the 

applicable tax and special assessment records, order refund by direct payment to Petitioner, not 

‘credit unless Petitioner expressly agrees in writing, of any amount paid with applicable interest, 

and grant any further relief necessary to prevent continued collection of an unauthorized special 

assessment. 

i 

Petitioner relies on the separate and specific facts stated in the Petition, Attachments A—F, and 

Exhibits 1-15, including Detroit’s failure to produce the Sherwood Forest petition summary, 

City-certified 51% land-area verification, Administering Department report, tentative 

assessment roll, stand-alone Sherwood Forest resolution, final resolution, confirmed special 

assessment roll, Clerk endorsement, delivery-to-Treasury record, annual 

accounting/redetermination record, and tax parcel share calculation required by Detroit City Code 

Division 8. 

Respectfully submitted, 

Cletrs Hondo K 

Cletis Kendrick, Petitioner 

19130 Parkside 

Detroit, MI 48221 

Phone: 

Email: 

Date: 

(313) 244-7249 

cbkendrick{@att.net 

07/1 6/L02¢ 

Attachment A — Page 2 of 2

CLETIS KENDRICK, 

Petitioner 

v. 

CITY OF DETROIT, 

Respondent 

ATTACHMENT B — PETITIONER’S PRELIMINARY STATEMENT AND FILING THEORY 

Petitioner, Cletis Kendrick, is the record owner/taxpayer for the residential property located at 19130 

Parkside, Detroit, Michigan 48221, Parcel No. 02004962.001, within the Sherwood Forest SAD area of 

Detroit. 

Petitioner’s correct legal name is Cletis Kendrick. Certain City of Detroit parcel, tax, or assessment 

records may incorrectly identify Petitioner as “Cleatis Kendrick,” which was the spelling of 

Petitioner’s father’s name. Petitioner inherited the subject property from his father. Any City record 

using “Cleatis Kendrick” in connection with the subject parcel should be understood as referring to the 

same property ownership chain and the parcel now owned by Petitioner, Cletis Kendrick. 

Petitioner challenges the City of Detroit’s lawful authority to impose and continue collecting the current 

2026 SMS/SWF special assessment charge on Petitioner’s Sherwood Forest tax parcel. The 2026 

charge is derivative of Detroit’s claimed 2023 Sherwood Forest SAD renewal, and Detroit must prove 

the lawful authority chain on which the current charge depends. 

This is an authority-chain challenge. Detroit has not produced the Sherwood Forest legal records 

required to convert a private neighborhood-association renewal request into a compulsory public special 

assessment enforceable through the property-tax bill. 

Detroit City Code Division 8 required the City to establish and preserve a traceable statutory and 

ordinance record chain before the claimed Sherwood Forest SAD renewal could become a compulsory 

special assessment billed through the property-tax system. That chain includes, at minimum: 

1. Lawful DNIO certification for Sherwood Forest Association;

2. A completed Sherwood Forest petition submitted to the City Clerk;

3. A petition summary showing record-owner signatures representing not less than 51% of the

land area within the Sherwood Forest SAD boundaries, measured by square footage;

4. Clerk receipt, filing, and forwarding of the petition to the Administering Department;

5. Administering Department review and report verifying petition validity;

6. A tentative assessment roll prepared by the Board of Assessors and included with the report to

City Council;

7. A Sherwood Forest-specific Council SAD resolution fixing the time and place of the public

hearing;

8. Legally sufficient public notice stating the proposed services, term, estimated annual and

aggregate costs, boundaries, tentative roll, and estimated tax parcel share;

Attachment B — Page 1 of 3

9. Valid SAD public hearings with the required DNIO participation and meaningful opportunity for

affected record owners to be heard;

10. A final Council resolution containing all Division 8 findings;

11. A special assessment roll prepared by the Board of Assessors;

12. Council confirmation of that special assessment roll;

13. Clerk endorsement of the confirmation date on the roll;

14. Clerk delivery of the confirmed roll to the Board of Assessors, Treasurer, and Sherwood Forest

Association;

15. Annual accounting and redetermination records supporting the 2026 tax parcel share; and

16. A lawful Treasury billing record tying the 2026 SMS/SWF charge to the confirmed Sherwood

Forest special assessment roll.

Detroit has not produced this authority chain. 

The record instead shows a broken process. On June 7, 2023, the City Clerk’s Office identified that a 

resolution was required to set the public hearing and that no resolution had been attached. Deputy CFO / 

Assessor Alvin Horhn admitted the resolution had not been submitted. The item was nevertheless 

advanced “pending” submission of the resolution. On June 13, 2023, City Council approved the hearing 

request with waiver, while the listed attachments included Detroit Golf Club and Palmer Woods 

resolutions but no Sherwood Forest resolution. 

On October 11, 2023, after the first purported public hearing had already occurred, the Clerk again 

asked Horhn whether he would provide a resolution. The record still does not show a stand-alone 

Sherwood Forest renewal resolution. 

The missing Sherwood Forest resolution is not a clerical defect. It is a missing legal predicate. Without 

the Sherwood Forest resolution, tentative assessment roll, notice record, final resolution, confirmed roll, 

Clerk endorsement, and delivery-to-Treasury record, Detroit cannot establish lawful authority to bill 

Petitioner’s parcel. 

The petition defect is independent and decisive. MCL 117.5i and Detroit City Code Division 8 require 

petition support from record owners of not less than 51% of the land area within the SAD 

boundaries, measured by square footage. Deputy CFO / Assessor Alvin Horhn’s public presentations 

repeatedly described support as a percentage of residents, taxpayers, property owners, or required 

signatures, rather than as record-owner signatures representing not less than 51% of the land area. 

Petitioner’s reconstructed petition-support roll and land-area analysis shows that Sherwood Forest did 

not satisfy the required 51% land-area threshold. Detroit has not produced the official Sherwood Forest 

petition summary, Administering Department report, tentative assessment roll, or required City-certified 

51% land-area calculation proving otherwise. 

The DNIO defect is independently material. Sherwood Forest Association was dissolved by operation 

of law from December 1, 2016, until January 31, 2023. Petition activity occurring in 2021 and 2022 

therefore occurred while SFA was not in lawful good standing. Detroit City Code Division 8 required 

a designated neighborhood improvement organization to be a Michigan nonprofit corporation in 

good standing. 

Attachment B — Page 2 of 3

Detroit cannot rely on SFA’s petition activity, renewal sponsorship, administration, or fund-receiving 

role unless Detroit proves lawful DNIO certification, good-standing verification, petition validation, and 

compliance with Division 8. 

The hearing and notice defects are independently material. Detroit has not produced a Sherwood Forest-

specific first-hearing notice record, proof of mailed notice, mailing-label record, publication proof, 

Clerk-filed tentative assessment roll, or public-examination record for the October 11, 2023, first public 

hearing. The November 8, 2023, second public hearing did not occur as scheduled. The November 15, 

2023, revised hearing proceeded without a demonstrated Sherwood Forest-specific notice chain, without 

a produced Sherwood Forest resolution, without a produced tentative assessment roll, and without 

Sherwood Forest Association testimony or Sherwood Forest resident support in the record. Public 

comment raised unresolved objections concerning benefit, equity, City trust, and petition verification. 

The City Council Budget, Finance and Audit Standing Committee nevertheless advanced the combined 

SAD renewal with waiver to Formal Session. 

The November 21, 2023, combined approval did not cure the missing authority chain. A combined 

renewal vote with waiver cannot substitute for the Sherwood Forest-specific records Division 8 required 

before Treasury billing: petition summary, Administering Department report, tentative assessment roll, 

public-hearing resolution, final findings, confirmed special assessment roll, Clerk endorsement, delivery 

to Treasury, and annual accounting/redetermination. 

The 2026 SMS/SWF charge is therefore legally unsupported unless Detroit proves the complete 

Sherwood Forest authority chain. A 2026 billing list, assessment extract, Treasury processing record, or 

annual redetermination record cannot retroactively create the claimed 2023 renewed seven-year term. 

Division 8 requires the term to commence from Council’s confirmation of the special assessment roll. A 

later annual billing or redetermination roll is derivative; it cannot cure the absence of the original 

confirmed Sherwood Forest roll. 

Petitioner requests that the Tribunal determine that the 2026 Sherwood Forest SMS/SWF special 

assessment charge is unauthorized unless Detroit produces the Sherwood Forest petition summary, 

Administering Department report, tentative assessment roll, stand-alone Sherwood Forest resolution, 

final resolution, confirmed special assessment roll, Clerk endorsement, delivery-to-Treasury record, 

annual accounting/redetermination record, and tax parcel share calculation required by City Code 

Division 8. 

Petitioner further requests cancellation of the 2026 SMS/SWF charge against Petitioner’s parcel, 

correction of the applicable tax and special assessment records, refund by direct payment to Petitioner, 

not credit unless Petitioner expressly agrees in writing, of any amount paid with applicable interest, and 

any further relief necessary to prevent continued collection of an unauthorized special assessment. 

Attachment B — Page 3 of 3

ATTACHMENT C 

JURISDICTION AND TRIBUNAL AUTHORITY 

The Michigan Tax Tribunal has jurisdiction over this appeal because Petitioner seeks direct review of a 

special assessment imposed by the City of Detroit against Petitioner’s real property. 

This appeal challenges the City of Detroit’s current 2026 SMS/SWF special assessment charge in the 

amount of $300.00, imposed against Parcel No. 02004962.001, located at 19130 Parkside, Detroit, 

Michigan 48221. The challenged charge arises from Detroit’s claimed 2023 renewal of the Sherwood 

Forest Special Assessment District for snow removal, mosquito abatement, and security services under 

MCL 117.5i and Detroit City Code Division 8. 

The challenged SMS/SWF charge is a special assessment imposed through the property-tax system. It is 

imposed against real property, tied to a claimed special assessment district, billed on the property-tax 

bill, and enforceable through property-tax collection mechanisms unless cancelled or corrected. 

Petitioner therefore invokes the Tribunal’s authority to determine whether Detroit had lawful authority to 

impose and continue collecting the current 2026 SMS/SWF charge. 

This is not an abstract political dispute and not a request for the Tribunal to supervise neighborhood 

services. Petitioner asks the Tribunal to decide whether Detroit established the legal authority required to 

impose a compulsory special assessment against Petitioner’s parcel. That issue falls within the 

Tribunal’s jurisdiction because it concerns the validity, assessment, collection, and continuing 

enforceability of a special assessment imposed under property-tax law. 

The Tribunal’s jurisdiction is further supported by Wilcoxon v Duggan, unpublished per curiam opinion 

of the Court of Appeals, issued March 18, 2026, Docket No. 373891. Wilcoxon involved a Detroit 

special assessment district renewal for snow removal, mosquito abatement, and security services under 

MCL 117.5i. The Court held that a direct challenge to the validity of such a Detroit SAD renewal falls 

within the Michigan Tax Tribunal’s exclusive and original jurisdiction. Petitioner’s appeal presents the 

same jurisdictional category: a direct challenge to the validity, authority, and continuing enforceability of 

a Detroit special assessment imposed against real property. 

The 2026 SMS/SWF charge is derivative of Detroit’s claimed 2023 Sherwood Forest SAD renewal. 

Detroit must therefore prove the 2023 renewal authority chain on which the current 2026 charge 

depends. A tax-bill entry, later billing list, Treasury processing record, annual redetermination record, or 

assessment extract cannot independently cure a defective or unlawful 2023 renewal. 

Petitioner’s jurisdictional position is straightforward: if Detroit claims authority to impose and continue 

collecting the 2026 SMS/SWF charge, Detroit must prove that the claimed 2023 Sherwood Forest SAD 

renewal was lawfully petitioned, verified, publicly noticed, heard, approved, confirmed by special 

assessment roll, endorsed by the Clerk, delivered to Treasury, and annually administered under MCL 

117.5i and Detroit City Code Division 8. 

Detroit cannot defeat jurisdiction by asserting that Petitioner failed to protest at a lawful Sherwood 

Forest roll-confirmation hearing unless Detroit first proves that such a hearing existed, was lawfully 

noticed, and concerned a Clerk-filed Sherwood Forest special assessment roll presented for 

confirmation. 

Attachment C — Page 1 of 3

Petitioner disputes that any lawful Sherwood Forest roll-confirmation hearing occurred. Detroit has not 

produced a Sherwood Forest-specific roll-confirmation hearing notice, proof of mailed notice, 

mailing-label record, publication proof, Clerk-filed tentative assessment roll, confirmed special 

assessment roll, Clerk endorsement, or Clerk delivery of the confirmed roll to Treasury. 

The absence of a valid protest opportunity is directly tied to Detroit’s own record defects. On June 7, 

2023, Deputy CFO / Assessor Alvin Horhn stated that the City Clerk needed at least 10 business days to 

receive mailing labels from the Office of the Assessor and notify residents in the affected areas. At the 

same meeting, the Clerk’s Office stated that a resolution was required to set the public hearing and that 

no resolution had been attached. Horhn admitted that the required resolution had not been submitted. 

The item was nevertheless advanced pending submission of the resolution. 

On June 13, 2023, the Formal Session record still identified the SAD hearing-setting item as 

“PENDING THE RESOLUTION.” The same record identified Detroit Golf Club and Palmer Woods 

resolution files but did not identify a comparable Sherwood Forest-specific resolution file. City 

Council nevertheless approved the hearing-setting item with waiver. 

On October 11, 2023, after the first purported public hearing had already occurred, the Clerk again 

asked whether Horhn would provide a resolution. Detroit has still not produced a stand-alone 

Sherwood Forest renewal resolution, Clerk-filed tentative assessment roll, first-hearing notice record, 

or public-examination record supporting that purported hearing process. 

The second-hearing process was also defective. The public hearing scheduled for November 8, 2023, 

did not occur as a Sherwood Forest SAD renewal hearing. Detroit has not produced a notice cancelling 

the November 8 hearing, a notice rescheduling it to November 15, 2023, a Clerk or Assessor notice 

mailed to Sherwood Forest record owners, or any Sherwood Forest Association notice to affected record 

owners. The November 15, 2023, hearing therefore cannot be treated as a lawful substitute for a properly 

noticed hearing without Detroit producing the required notice and authority-chain records. 

Because Detroit has not produced the required Sherwood Forest-specific notice, hearing, roll, 

confirmation, endorsement, and Treasury-delivery records, Detroit cannot establish that Petitioner 

received the legally required opportunity to protest or that any protest bar was triggered. 

The protest bar cannot be applied to Petitioner on this record. A protest requirement tied to a roll-

confirmation hearing presupposes lawful notice, an identifiable roll-confirmation hearing, a Clerk-filed 

special assessment roll, and a meaningful opportunity to object before confirmation. Detroit has not 

produced those predicate records for Sherwood Forest. Without those records, Detroit cannot establish 

that the protest requirement was triggered, that Petitioner received the legally required opportunity to 

protest, or that Petitioner waived the right to challenge the current 2026 charge. 

Petitioner first became aware of the claimed 2023 Sherwood Forest SAD renewal after Detroit began 

billing the renewal charge through the property-tax system, including the 2024 split SMS/SWF billing 

sequence and the later continued $300 SMS/SWF annual billing. Petitioner then investigated the renewal 

record and discovered that Detroit had not produced the Sherwood Forest authority-chain records 

required to support the claimed renewed term and continued billing. 

Petitioner’s appeal is properly filed in the Entire Tribunal Division. Although the 2026 charge imposed 

against Petitioner’s parcel is $300.00, this case is not a simple arithmetic or valuation dispute. It is a 

legal-authority challenge requiring formal review of Detroit’s Division 8 authority chain, including 

Attachment C — Page 2 of 3

petition validity, DNIO certification, public-hearing authority, notice, roll confirmation, Clerk 

endorsement, Treasury billing authority, annual accounting, redetermination, and the lawful basis for 

continuing collection. 

The Tribunal therefore has authority to determine whether the 2026 Sherwood Forest SMS/SWF 

charge is lawful, whether Detroit has produced the required authority chain, whether the charge 

should be canceled, whether any amount paid should be refunded by direct payment to Petitioner, not 

credited unless Petitioner expressly agrees in writing, with applicable interest, and whether further 

relief is necessary to prevent continued collection of an unauthorized special assessment. 

Attachment C — Page 3 of 3

ATTACHMENT D 

STATEMENT OF ISSUES PRESENTED 

1. Whether the City of Detroit had lawful authority to impose and continue collecting the current

2026 Sherwood Forest SMS/SWF special assessment charge against Petitioner’s parcel when

the charge is derivative of Detroit’s claimed 2023 Sherwood Forest SAD renewal.

2. Whether the 2026 SMS/SWF charge is unauthorized unless Detroit proves the mandatory

authority-chain requirements required by MCL 117.5i and Detroit City Code Division 8,

including the Sherwood Forest petition summary, Administering Department report, tentative

assessment roll, Sherwood Forest-specific resolution, final resolution, confirmed special

assessment roll, Clerk endorsement, delivery-to-Treasury record, annual

accounting/redetermination record, and tax parcel share calculation.

3. Whether Detroit’s claimed 2023 Sherwood Forest SAD renewal is legally defective because

Petitioner’s reconstructed parcel-level land-area review shows only 1,510,860 sq. ft. of valid

signed record-taxpayer parcel land area, representing 29.89% of the total SAD parcel land area,

which is below the required 51% land-area threshold under MCL 117.5i and Detroit City Code

Division 8.

4. Whether Detroit’s claimed 2023 Sherwood Forest SAD renewal is legally defective because

Detroit has not produced a petition summary or City-certified 51% land-area calculation

showing record-owner signatures representing not less than 51% of the land area within the

Sherwood Forest SAD boundaries, measured by square footage.

5. Whether Sherwood Forest Association could lawfully serve as the petitioning, sponsoring,

administering, or fund-receiving DNIO for a compulsory public special assessment when SFA

was dissolved by operation of law from December 1, 2016, until January 31, 2023, and

petition activity occurred in 2021 and 2022 while SFA was not in lawful good standing.

6. Whether Detroit’s hearing-setting process was defective from inception where, on June 7, 2023,

the Clerk’s Office identified that a resolution was required and that no resolution had been

attached, Deputy CFO / Assessor Alvin Horhn admitted the resolution had not been submitted,

and the item was nevertheless advanced “pending” submission of the resolution.

7. Whether Detroit’s claimed Sherwood Forest renewal process remained defective where, on June

13, 2023, the Formal Session item still appeared as “PENDING THE RESOLUTION,” City

Council approved the hearing-setting item with waiver, and the reviewed attachment record

identified Detroit Golf Club and Palmer Woods resolution files but no comparable Sherwood

Forest-specific resolution file.

8. Whether Detroit’s first-hearing process was invalid where, on October 11, 2023, after the first

purported public hearing had already occurred, the Clerk again asked Horhn whether he would

provide a resolution, and Detroit still had not produced a stand-alone Sherwood Forest resolution,

Clerk-filed tentative assessment roll, public-examination record, or Sherwood Forest-specific

notice-supporting authority materials.

Attachment D — Page 1 of 2

9. Whether any post-hearing combined resolution or later combined multi-district document could 

retroactively supply the Sherwood Forest-specific legal foundation required before the October 

11, 2023, first public hearing, public notice, public examination, and protest opportunity.

10. Whether a combined newspaper publication, standing alone, provided a meaningful and legally 

sufficient protest opportunity for affected Sherwood Forest record owners where Detroit has not 

produced the Clerk mailed-notice chain, mailing-label transmittal, proof of mailed notice, 

Sherwood Forest-specific resolution, Clerk-filed tentative assessment roll, or public-examination 

record required to support the first public hearing.

11. Whether Detroit can rely on any protest bar against Petitioner when Petitioner did not receive 

mailed notice of a lawful Sherwood Forest roll-confirmation hearing and Detroit has not 

produced a Sherwood Forest-specific roll-confirmation hearing notice, confirmed special 

assessment roll, Clerk endorsement, or delivery-to-Treasury record.

12. Whether the November 15, 2023, revised public hearing was legally insufficient because the 

November 8, 2023, public hearing did not occur as a Sherwood Forest SAD renewal hearing, 

Detroit has not produced a cancellation or rescheduling notice, and the revised hearing could not 

have satisfied the City’s own stated 10-business-day notice requirement.

13. Whether the claimed renewal was invalid because the hearing record identifies no Sherwood 

Forest Association president, executive director, or authorized qualified representative attending 

either public hearing, despite Division 8’s DNIO attendance requirement, and no Sherwood 

Forest resident public comment at either public hearing.

14. Whether Detroit’s November 21, 2023, combined approval with waiver cured the missing 

Sherwood Forest authority-chain records required by Division 8, including the Sherwood Forest-

specific resolution, confirmed roll, Clerk endorsement, delivery to Treasury, and annual 

accounting/redetermination records.

15. Whether any 2026 billing list, Treasury processing record, annual redetermination record, 

assessment extract, or tax-bill entry can retroactively create or cure the original claimed 2023 

Sherwood Forest renewed term when Division 8 requires the term to commence from Council 

confirmation of the special assessment roll.

16. Whether Petitioner is entitled to cancellation of the 2026 SMS/SWF charge, correction of 

Petitioner’s tax and special assessment records, refund by direct payment to Petitioner, not credit 

unless Petitioner expressly agrees in writing, of any amount paid with applicable interest, and 

further relief necessary to prevent continued collection of an unauthorized special assessment.

Attachment D — Page 2 of 2

ATTACHMENT E 

PETITION LAND-AREA VERIFICATION SUMMARY 

Petitioner submits this Attachment E to summarize the petition land-area defect supporting this appeal of 

the current 2026 Sherwood Forest SMS/SWF special assessment charge. 

This attachment is not offered as a substitute for Detroit’s required official records. It is offered because 

Detroit has not produced the official Sherwood Forest petition summary, parcel-by-parcel 51% land-

area verification worksheet, Administering Department petition-validity report, tentative assessment 

roll, or other City-certified calculation establishing that the claimed 2023 Sherwood Forest SAD renewal 

petition satisfied MCL 117.5i and Detroit City Code Division 8. 

I. CONTROLLING REQUIREMENT

The controlling petition requirement is not a majority of residents, a majority of homeowners, a majority 

of taxpayers, or a majority of signatures. 

The controlling requirement is petition support from record owners representing not less than 51% of 

the land area within the Sherwood Forest Special Assessment District boundaries measured by square 

footage. 

That requirement is the statutory gateway. Unless the petition satisfied the 51% land-area threshold, 

Detroit lacked authority to advance the claimed 2023 Sherwood Forest SAD renewal to public hearing, 

roll confirmation, Treasury transmittal, billing, collection, or continued annual assessment. 

II. CITY NONPRODUCTION OF OFFICIAL VERIFICATION

Detroit has not produced the official records that should show whether the claimed 2023 Sherwood 

Forest SAD renewal petition satisfied the 51% land-area requirement. 

The missing official records include, but are not limited to: 

1. The Sherwood Forest petition summary;

2. The parcel-by-parcel 51% land-area verification worksheet;

3. The Administering Department petition-validity report;

4. The tentative assessment roll;

5. The City-certified calculation showing total district land area, valid signed land area, and

percentage of land represented by valid record-owner signatures;

6. Any record identifying signatures excluded, duplicated, invalidated, unverifiable, unsupported by

record ownership, or unsupported by authority to sign.

Because Detroit has not produced those records, Petitioner manually reconstructed the petition land-area 

verification from the City-produced Sherwood Forest petition records and City parcel land-area 

information. 

III. PETITIONER’S MANUAL RECONSTRUCTION

Petitioner manually reviewed the City-produced Sherwood Forest petition records against parcel-level 

ownership and land-area information to determine whether the petition satisfied the statutory land-area 

threshold. 

Attachment E — Page 1 of 3

Petitioner performed this reconstruction because Detroit did not produce the official City verification 

required to substantiate the claimed 2023 renewal before imposing and continuing the 2026 SMS/SWF 

charge. 

Petitioner’s reconstruction focused on the controlling statutory question at the petition stage: 

Whether valid record-owner signatures represented not less than 51% of the land area within the 

Sherwood Forest SAD boundaries. 

IV. SUMMARY OF RECONSTRUCTED LAND-AREA RESULT

Petitioner’s reconstructed land-area review shows the following: 

Total Sherwood Forest SAD parcel land area: 5,054,317 sq. ft. 

Required 51% land-area threshold: 2,577,702 sq. ft. 

Valid signed record-taxpayer parcel land area: 1,510,860 sq. ft. 

Valid signed land-area percentage: 29.89% 

Land-area shortfall: 1,066,842 sq. ft. 

Based on Petitioner’s reconstruction, the claimed 2023 Sherwood Forest renewal petition did not satisfy 

the required 51% land-area threshold necessary to support the current 2026 SMS/SWF charge. 

V. MATERIAL PETITION-VALIDITY CATEGORIES REVIEWED

In reconstructing the land-area calculation, Petitioner reviewed whether petition entries could be counted 

as valid support for the statutory land-area threshold. 

The petition-validity review included, among other things: 

1. Whether the signer matched the record taxpayer / record owner for the parcel;

2. Whether each parcel’s land area was counted only once;

3. Whether duplicate signatures were improperly counted more than once;

4. Whether signatures were collected before the 2023 renewal process while Sherwood Forest

Association was dissolved by operation of law and not in lawful good standing;

5. Whether signatures were collected in 2021 or 2022 and later used for the claimed 2023 renewal;

6. Whether trust, estate, corporate, or entity-owned parcels were signed by a person with apparent

authority to bind the record owner;

7. Whether petition sheets contained missing signatures, missing printed names, missing dates, or

other facial defects;

8. Whether petition entries reflected taxpayer / signer mismatches;

9. Whether manually altered or handwritten ownership changes affected the ability to verify the

petition entry;

10. Whether the City-produced petition sheets contained the certifications, signatures, dates, and

organizational verification necessary to support reliance on the petition record.

These categories matter because only valid record-owner land-area support may be counted toward the 

statutory 51% land-area threshold. 

Attachment E — Page 2 of 3

VI. WHY THE DEFECT IS DECISIVE

The 51% land-area requirement is not a technical formality. It is the legal threshold that determines 

whether Detroit had authority to proceed with the Sherwood Forest SAD renewal at all. 

If the petition did not satisfy the 51% land-area requirement, Detroit could not lawfully cure that 

failure through a later public hearing, combined resolution, waiver vote, annual billing list, tax-bill entry, 

assessment extract, or Treasury collection process. 

A later billing record cannot create petition support that did not exist at the statutory gateway stage. 

VII. RELATION TO DETROIT’S BURDEN

Petitioner does not contend that his reconstruction substitutes for Detroit’s legal duty to produce the 

official City records required by MCL 117.5i and Detroit City Code Division 8. 

Petitioner contends that Detroit has not produced the official records needed to prove petition 

sufficiency, and that Petitioner’s reconstruction affirmatively shows that the required land-area threshold 

was not met. 

If Detroit contends that the petition satisfied MCL 117.5i and Division 8, Detroit should be required to 

produce the official Sherwood Forest petition summary, parcel-by-parcel land-area worksheet, 

Administering Department petition-validity report, tentative assessment roll, and underlying parcel-level 

calculation on which the City relied before advancing the renewal to public hearing, confirmation, 

billing, collection, and continued annual assessment. 

VIII. CONCLUSION

Detroit has not produced a City-certified land-area verification measured by square footage showing 

that the Sherwood Forest renewal petition satisfied the required 51% land-area threshold. 

Petitioner’s reconstructed land-area verification shows only 1,510,860 sq. ft. of valid signed record-

taxpayer parcel land area, representing only 29.89% of the total Sherwood Forest SAD parcel land area, 

with a shortfall of 1,066,842 sq. ft. 

Accordingly, the Sherwood Forest renewal petition failed the statutory gateway requirement. Without 

lawful 51% land-area support, measured by square footage, Detroit lacked authority to proceed to 

renewal, roll confirmation, Treasury transmittal, billing, collection, or continued imposition of the 2026 

SMS/SWF charge against Petitioner’s parcel. 

Attachment E — Page 3 of 3

ATTACHMENT F 

CORE EXHIBIT INDEX 

Petitioner submits the following core exhibits in support of his appeal from the current 2026 SMS/SWF 

special assessment charge imposed on Parcel No. 02004962.001 under Detroit’s claimed 2023 renewal 

of the Sherwood Forest Special Assessment District. 

These exhibits are submitted to establish the current charge being appealed, the continuing billing 

sequence, the governing Division 8 authority requirements, Detroit’s missing or defective renewal 

record, the missing roll-confirmation and billing-authority chain, and Petitioner’s repeated efforts to 

obtain the official records required to substantiate the charge. 

CORE EXHIBITS 

Exhibit 1 — 2026 City of Detroit Summer Property Tax Bill Showing $300 SMS/SWF Special 

Assessment Charge 

Purpose: Establishes the current 2026 tax-year charge being appealed. The bill shows the $300 

SMS/SWF charge imposed on Parcel No. 02004962.001, 19130 Parkside, Detroit, Michigan. 

Exhibit 2 — 2024 Summer Property Tax Bill Showing $250 SMS/SWF Special Assessment Charge 

Purpose: Shows Detroit’s initial 2024 Summer billing of the Sherwood Forest SMS/SWF charge at $250 

following the claimed 2023 renewal. 

Exhibit 3 — 2024 Corrected Winter Property Tax Bill Showing $50 SMS/SWF Special Assessment 

Charge 

Purpose: Shows Detroit’s later 2024 Winter correction billing of an additional $50 SMS/SWF charge, 

completing the $300 claimed renewal amount for 2024. 

Exhibit 4 — Assessor Billing-Correction Notice Explaining $250 Summer and $50 Winter 

SMS/SWF Charges 

Purpose: Shows Detroit’s explanation that the Sherwood Forest fee was renewed at $300, that $250 was 

billed on the 2024 Summer tax bill, that an additional $50 would be billed on the 2024 Winter tax bill, 

and that future years would reflect the full $300 charge. The notice is relevant as a billing explanation, 

not as proof of lawful renewal authority. 

Exhibit 5 — 2025 Summer Property Tax Bill Showing Continued $300 SMS/SWF Special 

Assessment Charge 

Purpose: Shows that Detroit continued billing the Sherwood Forest SMS/SWF charge at $300 in 2025, 

demonstrating that the claimed 2023 renewal was treated by Detroit as a continuing annual charge. 

Exhibit 6 — Detroit City Code Division 8 — Mandatory Authority-Chain Requirements for 

SMS/SWF Special Assessments 

Purpose: Provides the governing local ordinance provisions for the creation, continuation, petition 

verification, Administering Department report, tentative assessment roll, public hearing, roll 

confirmation, Clerk endorsement, Treasury delivery, collection, and annual administration of Detroit 

snow-removal, mosquito-abatement, and security-service special assessment districts. 

Attachment F — Page 1 of 4

Exhibit 7 — June 7, 2023, BFA Missing-Resolution Record 

Purpose: Shows that the Budget, Finance and Audit Standing Committee process identified a missing 

resolution at the beginning of the 2023 special assessment renewal process and that Deputy CFO / 

Assessor Alvin Horhn acknowledged that no resolution had been submitted. 

Exhibit 8 — June 13, 2023, Formal Session eSCRIBE Agenda Package and Comparator 

Attachment Record 

Purpose: Shows that the June 13, 2023, Formal Session record continued to identify the matter as 

pending resolution and that the reviewed attachment record identified Detroit Golf Club and Palmer 

Woods resolution materials, but no comparable Sherwood Forest-specific resolution. 

Exhibit 9 — Detroit Golf Club and Palmer Woods Comparator Resolution Records 

Purpose: Shows that Detroit prepared and maintained district-specific resolution records for Detroit Golf 

Club and Palmer Woods. These comparator records support the significance of the missing comparable 

Sherwood Forest-specific authority record. Petitioner does not use this exhibit to challenge the Detroit 

Golf Club or Palmer Woods districts. 

Exhibit 10 — October 13, 2023, Post-First-Hearing Combined Multi-District Renewal Resolution 

Purpose: Shows that the combined Detroit Golf Club / Palmer Woods / Sherwood Forest renewal 

resolution was dated after the October 11, 2023, first public hearing and therefore could not have served 

as the pre-hearing Sherwood Forest-specific resolution, tentative roll, Clerk-filed public-examination 

record, or notice-supporting authority material for that hearing. 

Exhibit 11 — Repeated Requests for Missing Sherwood Forest Resolution and October 11, 2023, 

First-Hearing Defect 

Purpose: Shows the repeated requests for the missing Sherwood Forest resolution and the defect in the 

October 11, 2023, first public-hearing process, including the absence of attached Sherwood Forest-

specific authority materials in the reviewed hearing record. 

Exhibit 12 — November 15, 2023, Second-Hearing Notice Defect 

Purpose: Shows the defect in the second-hearing sequence, including the noticed November 8, 2023, 

hearing date, the absence of the noticed SAD hearing on the November 8, 2023, BF&A agenda, the later 

November 15, 2023, hearing, and the absence of a produced cancellation, rescheduling, or renewed 

mailed-notice record for affected Sherwood Forest owners. 

Exhibit 13 — FOIA Petition-Records Request, April 2025 Production, and Disputed 2022 

Signature Source 

Purpose: Shows that Petitioner requested the Sherwood Forest SAD petition records and that Detroit 

produced petition records in April 2025, which became part of Petitioner’s later review of the petition 

and signature record, including the disputed use of Petitioner’s 2022 signature. 

 

Attachment F — Page 2 of 4

Exhibit 14 — FOIA Request for Administering Department Report and Tentative Assessment Roll 

Purpose: Shows that Petitioner specifically requested the Administering Department report and tentative 

assessment roll required to substantiate Detroit’s claimed petition verification and pre-hearing authority 

for the 2023 Sherwood Forest SAD renewal. 

Exhibit 15 — Beal / Kelly Clerk Archive and FOIA Nonresponse Record 

Purpose: Shows that Law Department / FOIA was waiting on the Clerk’s Office, that the Clerk archive 

materials located were identified as limited notice and resolution / roll-call materials, and that the 

reviewed Clerk archive / FOIA record did not identify the Division 8 authority-chain records required to 

support lawful 2023 Sherwood Forest renewal, confirmation, transmittal, billing, and collection. 

SUMMARY OF EXHIBIT PURPOSE 

Together, Exhibits 1 through 15 support Petitioner’s position that the current 2026 SMS/SWF charge is 

not supported by a produced legal-authority chain. The exhibits establish the current charge, the 

continuing billing pattern, the governing ordinance requirements, the missing or defective resolution and 

hearing sequence, the nonproduction of the Administering Department report and tentative assessment 

roll, the nonproduction of the confirmed roll and Clerk endorsement, and the nonproduction of Treasury 

billing authority. 

Petitioner does not contend that each exhibit independently proves the entire appeal. The exhibits are 

offered together to show the record sequence and the missing authority-chain records necessary to 

impose and continue collecting the current 2026 SMS/SWF charge. 

DOCUMENTS RESERVED FOR SUPPLEMENTAL RECORD APPENDIX 

Petitioner reserves the right to supplement the record with additional materials, including but not limited 

to: 

1. Full City Council and Committee transcript excerpts; 

2. Full FOIA correspondence and production records; 

3. Full City-produced Sherwood Forest petition production; 

4. Petition signature analysis; 

5. Reconstructed Sherwood Forest assessment roll and land-area calculation; 

6. Sherwood Forest Association LARA status records; 

7. Sherwood Forest Association IRS / nonprofit records; 

8. Additional Detroit Golf Club and Palmer Woods comparator records; 

9. Treasurer correspondence and billing-authority requests; 

10. Additional City Council agenda packets, minutes, and attachment records; 

11. Detroit Legal News publication records, including the October 3, 2023, combined public-hearing 

notice and any related publication proof, affidavit, request, or tear sheet; 

Attachment F — Page 3 of 4

12. Any later City production, no-records determination, FOIA response, or authority-chain record

produced after this filing;

13. Any supplemental tax-bill, payment, delinquency, refund, credit, or collection record relevant to

the 2026 SMS/SWF charge.

RESERVATION OF RIGHTS 

Petitioner reserves the right to rely on these exhibits, supplement these exhibits, attach additional 

records, request production of City-held authority-chain records, and respond to any record later 

produced by Detroit in support of the 2026 SMS/SWF charge. 

Petitioner further reserves the right to challenge any later-produced record on grounds including 

timeliness, authenticity, statutory sufficiency, legal effect, relevance, chain of custody, public-

examination availability, notice sufficiency, roll-confirmation sufficiency, Clerk endorsement, Treasury 

transmittal, billing authority, or compliance with MCL 117.5i and Detroit City Code Division 8. 

Attachment F — Page 4 of 4

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