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lawsuitappealhearingwillzoningregulationdue process
plaintiffappealwillzoningregulationdue process

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Greenbriar, Ltd. v. City of Alabaster, 881 F.2d 1570

Facts

In 1970, the city of Alabaster adopted a zoning ordinance that zoned the property in question as multi-family residential, which remained unchanged for 16 years. In 1986, the city rezoned the property to single-family residential and later received a request from Greenbriar, Ltd. to rezone it to Planned Development District (PDD). After public hearings and revisions to the proposal, the city council ultimately rejected the request, leading Greenbriar to file a lawsuit claiming a violation of their due process rights.

In 1970 the city of Alabaster (“City”) first adopted a zoning ordinance. The property at issue in this action, consisting of 76 acres, was zoned multi-family residential, which it remained for 16 years. In October 1986 the city adopted a new zoning ordinance and map, which rezoned the property at issue from multi-family residential to single-family residential.

Issue

Did the city council's rejection of the landowners' rezoning request constitute a violation of substantive due process?

Did the city council's rejection of the landowners' rezoning request constitute a violation of substantive due process?

Rule

Zoning regulations will not be declared unconstitutional unless they are clearly arbitrary and unreasonable, having no substantial relation to the public health, safety, morals, or general welfare.

Zoning regulations will not be declared unconstitutional as violative of substantive due process unless they “are clearly arbitrary and unreasonable, having no substantial relation to the public health, safety, morals, or general welfare.”

Analysis

The court determined that the city council's decision to deny the rezoning request was not arbitrary and capricious. It found that the council had a rational basis for its decision, considering community concerns about traffic, property values, and the impact on local infrastructure. The council's evaluation of the proposal in light of constituents' preferences did not deprive their decision of a rational basis.

The court determined that the city council's decision to deny the rezoning request was not arbitrary and capricious. It found that the council had a rational basis for its decision, considering community concerns about traffic, property values, and the impact on local infrastructure.

Conclusion

The Court of Appeals reversed the district court's judgment, concluding that the city's denial of the rezoning request was not arbitrary and capricious, and thus did not violate the landowners' substantive due process rights.

The Court of Appeals reversed the district court's judgment, concluding that the city's denial of the rezoning request was not arbitrary and capricious, and thus did not violate the landowners' substantive due process rights.

Who won?

City of Alabaster prevailed in the case because the court found that the city's decision to deny the rezoning request was based on a rational basis and not arbitrary or capricious.

The City of Alabaster appeals from a judgment of the district court holding that its rejection of plaintiffs' request for the rezoning of certain property constituted a violation of substantive due process.

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