Osiecki v. Town of Huntington
170 A.D.2d 490, 1991 N.Y. App. Div. LEXIS 2028, 565 N.Y.S.2d 564 (1991)
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Rule of Law:
A municipal zoning ordinance that contradicts the municipality's own comprehensive or master plan is invalid unless the municipality articulates a rational basis for deviating from the plan.
Facts:
- The plaintiffs own a five and one-half acre parcel of land in the Town of Huntington.
- The Town of Huntington has zoned this parcel for low-density residential use, permitting only one-acre plots.
- In 1965, the Town's planning board adopted a master plan designating the entire block, including the plaintiffs' parcel, for commercial development.
- The Town has followed this master plan for other properties, zoning two adjacent parcels to the west for commercial office buildings which have since been developed.
- The properties south and east of the parcel are zoned for residential use but are currently used as a farm and for water district purposes.
- The area north of the parcel is the Northern State Parkway and a town park.
- As recently as 1986, the Town Planning Board and Planning Department recommended that the plaintiffs' parcel be developed commercially, consistent with the master plan.
Procedural Posture:
- The plaintiffs filed an action in the Supreme Court, Suffolk County (a trial-level court) against the Town of Huntington.
- The action sought a judgment declaring the one-acre residential zoning of their property invalid.
- After a nonjury trial, the Supreme Court ruled in favor of the Town, declaring the zoning classification valid.
- The plaintiffs, as appellants, appealed the trial court's judgment to the Appellate Division of the Supreme Court (an intermediate appellate court).
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Issue:
Does a town's zoning ordinance that classifies a specific parcel for residential use, contrary to the town's own master plan which designates the area for commercial development, violate the statutory requirement that zoning be in accordance with a comprehensive plan when the town offers no reason for the deviation?
Opinions:
Majority - Brown, J. P.
Yes. A zoning classification that fails to comport with a town's comprehensive plan is void. Town Law § 263 requires that zoning ordinances be made in accordance with a comprehensive plan, which can be derived from sources like a master plan. The Town's 1965 master plan designated the subject property for commercial development, a plan the Town largely followed by rezoning adjacent parcels. While a town is not bound by 'slavish servitude' to its master plan and may deviate from it, such a deviation requires a rational justification. Here, the Town of Huntington offered no reason for its decision to disregard the master plan for this specific parcel. To allow a municipality to deviate from its plan without articulating a reason would invite the ad hoc and arbitrary use of zoning power that the comprehensive planning requirement was designed to prevent. Because the record establishes that commercial development was part of the Town's comprehensive plan and the Town provided no basis for changing it, the residential-only zoning is invalid.
Analysis:
This decision reinforces the legal significance of a comprehensive or master plan as a check on a municipality's zoning authority. It clarifies that while master plans are not immutable, they cannot be disregarded arbitrarily. The case establishes that a municipality bears the burden of justifying its departure from an established plan, thereby preventing ad hoc decision-making and ensuring that zoning changes are the result of reasoned planning. This holding protects property owners from arbitrary treatment and promotes predictability and coherence in land use regulation.
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