A recent federal lawsuit claims that local government officials retaliated against a property owner after he challenged their handling of a zoning permit, raising questions about the limits of municipal authority and the protection of constitutional rights for residents. The complaint was filed by L2JMO Associates, LLC, through its owner Dr. Shahram Jay Mirmanesh, in the United States District Court for the District of New Jersey on March 30, 2026. The defendants named are the Borough of Haddonfield along with Tavis A. Karrow (former Zoning Officer), Salvatore Siciliano (Borough Solicitor), Andrew Viola (Borough Prosecutor), and unidentified individuals referred to as John Does 1-10.
According to the filing, L2JMO Associates owns property at 50 Chews Landing Road in Haddonfield, New Jersey. In June 2019, the company applied for and received a zoning permit from the borough to construct a tennis court and make other improvements such as repairs to the driveway, fence, and balcony. The complaint states that construction began based on this permit but soon became subject to scrutiny by borough officials who raised concerns about compliance with local ordinances and requested additional surveys to verify adherence to zoning requirements.
The plaintiff alleges that despite providing multiple surveys—including one by Kelly Engineering in March 2020 and another by Ewing Consulting in November 2020—and submitting detailed compliance documentation with photographs, borough officials continued to insist on further measures beyond what was originally required. The ongoing disagreement centered on whether the improvements conformed to borough ordinances and if additional modifications or removals were necessary.
Tensions escalated on July 13, 2023 when counsel for L2JMO sent a letter to defendant Karrow asserting legal rights and challenging what they described as unreasonable enforcement actions by the borough. According to the complaint, “On the same date…the Borough filed multiple municipal complaints against Plaintiff in Haddonfield Municipal Court.” The filing emphasizes that “the temporal proximity between Plaintiff’s protected petitioning activity and the filing of the Municipal Complaints—both occurring on July 13, 2023—gives rise to a strong inference of retaliatory motive.” These municipal complaints were later adjudicated in court.
Settlement negotiations took place during these proceedings with a proposed consent agreement intended to resolve outstanding issues. However, according to L2JMO Associates’ account, “Defendants ultimately rejected the proposed consent resolution and declined to enter into the agreement previously outlined,” which led to trial instead of settlement. On November 26, 2024, Haddonfield Municipal Court found in favor of L2JMO Associates by dismissing all municipal complaints with prejudice—a decision that effectively ended those enforcement actions.
The lawsuit argues that this sequence shows not only retaliation for exercising First Amendment rights but also violations under substantive due process protections afforded by the Fourteenth Amendment. It alleges that “Defendants’ conduct—including…shifting compliance demands…retaliatory filing…rejection of a reasonable consent resolution…and forced prosecution through trial…was arbitrary, irrational, and conscience-shocking.” Additionally, it asserts an equal protection claim based on selective enforcement: “Defendants singled out Plaintiff for enforcement action while similarly situated property owners…were not subjected to municipal complaints or prosecution.”
Further claims include Monell liability against the Borough itself for alleged policies or customs leading to constitutional violations as well as state law abuse-of-process allegations. The complaint seeks compensatory damages covering legal fees, diminished property value, lost sale opportunities, emotional distress suffered by Dr. Mirmanesh personally as well as reputational harm; punitive damages against individual defendants; attorney’s fees; declaratory judgment confirming constitutional violations; damages for interference with use or enjoyment of property; and any other relief deemed appropriate by the court.
The case is represented by attorney Licardo E. Gwira (Attorney I.D. #000382012) based in Voorhees, New Jersey. The case identification number is Case 1:26-cv-03851.
Source: 126cv03851_L2JMO_Associates_LLC_v_Borough_of_Haddonfield_Complaint_District_New_Jersey.pdf
