Board of County Commissioners of Brevard County v. Snyder
627 So. 2d 469 (1993)
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Rule of Law:
When a landowner seeks to rezone a specific parcel of property, the local government's action is quasi-judicial, not legislative. If the landowner proves the proposed use is consistent with the comprehensive plan, the burden shifts to the government to demonstrate by competent substantial evidence that maintaining the existing zoning accomplishes a legitimate public purpose.
Facts:
- Jack and Gail Snyder owned a one-half acre parcel of property in an unincorporated area of Brevard County.
- The property's zoning classification was GU (general use), which permitted the construction of a single-family residence.
- The Snyders applied to rezone their property to RU-2-15, a classification that allows for the construction of up to fifteen residential units per acre.
- Both the existing GU and the proposed RU-2-15 zoning classifications were potentially consistent with the county's 1988 Comprehensive Plan Future Land Use Map for that area.
- County planning staff, after initially recommending denial based on a flood plain issue, withdrew their opposition after learning the issue would be resolved by raising the land's elevation during development.
- At a meeting before the Board of County Commissioners, several citizens spoke in opposition to the rezoning request, citing concerns about increased traffic.
- The Board of County Commissioners voted to deny the Snyders' rezoning application without stating a reason for the denial.
Procedural Posture:
- The Snyders filed a petition for writ of certiorari in the circuit court to challenge the Board of County Commissioners' denial of their rezoning application.
- The circuit court, sitting en banc as an appellate court, denied the Snyders' petition by a two-to-one vote.
- The Snyders (Petitioners) then sought review by filing a petition for writ of certiorari in the Florida Fifth District Court of Appeal.
- The Fifth District Court of Appeal granted the petition and quashed the Board's decision, holding that the denial was arbitrary and unreasonable.
- The Board of County Commissioners of Brevard County (Petitioner) sought review in the Supreme Court of Florida due to a conflict between the appellate court's decision and other precedents.
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Issue:
Is a local government board's denial of a specific rezoning application for a single parcel of land a quasi-judicial action that, if the proposal is shown to be consistent with the comprehensive plan, shifts the burden to the board to prove the denial serves a legitimate public purpose?
Opinions:
Majority - Grimes, J.
Yes. A local government board's denial of a specific rezoning application is a quasi-judicial action, and once a landowner demonstrates the proposal's consistency with the comprehensive plan, the burden shifts to the government to justify the denial. The court held that rezoning actions affecting a limited number of persons or properties are quasi-judicial because they involve applying general policy to specific facts, rather than formulating broad new policy. Such actions are reviewable by certiorari and must be supported by competent substantial evidence. The court established a burden-shifting framework: 1) the landowner must prove the proposal is consistent with the comprehensive plan and complies with procedural requirements; 2) the burden then shifts to the government to show that maintaining the existing zoning accomplishes a legitimate public purpose and that the denial is not arbitrary, discriminatory, or unreasonable. This approach subsumes traditional remedies and requires the government to create a record sufficient to justify its decision.
Analysis:
This landmark decision fundamentally shifted Florida land use law by reclassifying site-specific rezoning decisions from legislative to quasi-judicial. Previously, such decisions were upheld if 'fairly debatable,' a highly deferential standard that made challenges very difficult. By requiring a quasi-judicial proceeding, the Court mandated stricter scrutiny and required that decisions be based on competent substantial evidence in the record. This change provides landowners with more meaningful judicial review and curtails the ability of local governments to deny consistent development plans based on political pressure or vague public opposition without providing legally sufficient reasons.
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