OLeary_PSD_Appeal.pdf

Amee L OLeary, Petitioner V City Of Lansing, Respondent · 25-003705-TT

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Principal Shopping District Special Assessment Protest 

Date: October 28, 2025 

Parcel #: 33-01-01-09-404-013 

Property Address: 1115 Center Street, Lansing, MI 48906 

Owners: Daniel S. O’Leary & Amee L. O’Leary 

Petition Form 

Petition Form to be Filed Electronically via Michigan Tax Tribunal Portal. 

Statement of Facts 

The subject property at 1115 Center Street, Lansing, Michigan is a 27,021 sq. ft. warehouse 

facility used exclusively for wholesale distribution. The building has no retail storefront and 

has never received walk-in customer traffic. The business sells to retailers, not to the public. 

The operations of the property do not rely on or benefit from pedestrian shopping activity. 

 

The Principal Shopping District (PSD) special assessment is designed to fund activities 

intended to increase retail shopping traffic, enhance the consumer experience, and support 

the commercial retail corridor in Old Town. These improvements do not confer a special or 

specific benefit to the subject property due to its wholesale use, non-retail operations, and 

private industrial access patterns. 

 

The property has been continuously owned by the same family since approximately 1980, 

first by the prior generation and now by the current owners since 2005. Throughout that 

time, the special assessment has been imposed, although the property’s use has not 

changed. The owners have consistently maintained that the assessment provides no direct 

benefit to the property and should not apply to a warehouse with no retail function. The 

special assessment has averaged approximately $500 per year, in addition to hefty property 

taxes. 

 

In 2023, the owner submitted a formal written protest to the PSD special assessment roll. In 

2024, the owner personally attended the public hearing but was never called to speak, 

despite signing in and remaining for the full duration of the meeting. In 2025, the owner 

again submitted a written protest on September 19, 2025, and received acknowledgment 

that the protest was entered into the hearing record. However, the owner has not received 

any written response addressing the concerns raised although requested. 

 

Based on use, access patterns, and the nature of the business, the property does not receive 

a special benefit that is different from the benefit to the general public, and therefore should 

not be subject to the Principal Shopping District special assessment. 

Exhibit Index 

Exhibit A – Property Photos (Provided by Owner) 

Exhibit B – Crime/Security Incident Summary 

Exhibit C – Record of Prior Protests

1115 Center Front View 

 

 

View from Grand River Avenue 

 

 

 

 

 

 

 

Rear of Building 

View 

from City Lot 

Top View 

of Building 

 bordered 

In Red

 

Exhibit A- Property Photos

Left: Homeless baggage in the immediate area 

outside our building, and close to the adjacent 

abandoned building. 

Below: Used needles left behind on our property.

Attempted Break in 2020

Exhibit B – Crime and Security Summary 

The following incidents have occurred at or near the subject property in recent years, 

illustrating the ongoing safety and security issues that affect the area and its lack of benefit 

from retail-oriented improvements: 

 

• Attempted Break-In – May 2020 

• Employee Carjacked – February 2023 (Police Report #2351901483) 

• Breaking & Entering / Office Ransacked – November 2024 (Police Report #2451910696) 

• Abandoned Building at 308 N. Cesar Chavez – Homeless Activity and Opioid Use – 

December 2023 (Report #E23-13475) 

 

These incidents demonstrate that the area continues to face challenges unrelated to retail 

development, further supporting that the property derives no special benefit from the 

assessment. 

Exhibit C – Record of Prior Protests 

The property owners have consistently objected to the Principal Shopping District Special 

Assessment over multiple years: 

 

• 2023 – Written protest submitted to City Clerk (no written response received) 

• 2024 – Attended public hearing, signed in, not called to speak 

• 2025 – Written protest submitted on September 19, 2025, acknowledged as received but 

unanswered 

 

This ongoing pattern of unanswered appeals demonstrates a lack of engagement with 

property owners directly affected by the assessment. 

Closing Statement 

This property has been subject to an annual retail improvement assessment for 

many years without receiving a single direct or measurable benefit. It remains a 

wholesale warehouse facility surrounded by industrial operations and security 

concerns — conditions entirely inconsistent with a retail district. Despite repeated 

written protests and attendance at hearings, no substantive response or 

consideration has been given. 

We strongly urge the Michigan Tax Tribunal to correct this ongoing inequity by 

removing this property from inclusion in the Principal Shopping District special 

assessment going forward. 

 

/s/ Daniel S. O’Leary 

/s/ Amee L. O’Leary 

Owners 

Dated: October 28, 2025

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