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Stillman v. Zoning Board of Appeals

Appellate Court of Connecticut
Sep 3, 1991
25 Conn. App. 631 (Conn. App. Ct. 1991)

Summary

In Stillman, the defendant landowner sought a variance of the town of Redding's coverage and setback regulations in order to build an addition to her house, which the Zoning Board of Appeals of the Town of Redding granted.

Summary of this case from E&F Assocs., LLC v. Zoning Bd. of Appeals of the Town of Fairfield

Opinion

(9736) (9737)

The plaintiff appealed to the trial court from a decision by the defendant zoning board of appeals of the town of Redding granting a variance to the defendant homeowner, M, to permit her to build an addition to her house. The trial court rendered judgment sustaining the plaintiff's appeal, and the defendants, on the granting of certification, appealed to this court. Held: 1. The trial court should not have determined that the board lacked the authority to grant the variance; by statute ( 8-6), zoning boards of appeals have the power to vary the application of zoning regulations, subject only to any explicit limitation on the issuance of variances contained in the regulations themselves, and the only limitation contained in the Redding zoning regulations prohibits the intensification of nonresidential uses in residential zones. 2. The trial court applied an incorrect legal test in determining that M had failed to establish a legally sufficient hardship to justify the granting of a variance; a variance may be granted if the literal enforcement of a regulation causes exceptional difficulty or hardship because of some unusual characteristic of the property not personal to the applicant, and it is not necessary to establish that the enforcement of the regulation would render the property practically worthless.

Argued April 23, 1991

Decision released September 3, 1991

Appeal by the plaintiff from a decision by the named defendant granting the application for a variance filed by the defendant Nancy H. Morgan, brought to the Superior Court in the judicial district of Danbury and tried to the court, Sylvester, J.; judgment sustaining the appeal, from which, on the granting of certification, the named defendant and the defendant Nancy H. Morgan filed separate appeals to this court. Reversed; judgment directed.

Michael N. LaVelle, for the appellant in the first appeal (named defendant).

Marylouise S. Black, for the appellant in the second appeal (defendant Nancy H. Morgan).

Thomas W. Beecher, for the appellee (plaintiff).


The defendants appeal from the judgment of the trial court reversing the defendant board's decision to grant a variance to the defendant homeowner, Nancy H. Morgan. Morgan sought a variance of coverage and setback regulations from the Redding zoning board of appeals (board) in order to build an addition onto her house. The plaintiff, who is an adjoining landowner, opposed this variance before the board, and took an appeal to the Superior Court after the variance was granted. The trial court held that the board did not have the authority to grant the variance and that Morgan failed to demonstrate a legally cognizable hardship, and, therefore, reversed the decision of the board.

Having been granted certification, the defendants appeal to this court claiming (1) that the board acted within its authority in granting the variance and (2) that a legally sufficient hardship existed on Morgan's property. We agree.

The board found the following facts. Morgan's property is rectangular in shape and faces the south side of South Lane in Redding. The lot is located in a two acre zone, but is a legally nonconforming one-half acre lot. Morgan's house is located on the east side of her property with a 26.9 foot setback at the western boundary of the plaintiff's lot. Morgan's garage is in the southeastern corner of her lot, between the house and the boundary line. The garage is also a legal nonconformity. Morgan's septic tank is located to the south of the house, and her well was drilled to the west of the house.

This matter arose because Morgan proposed to construct an addition to her house in order to add a bathroom and a laundry room to the first floor. Morgan proposed to make these renovations because of her advancing age. This addition would enlarge the house by ninety-eight square feet by enclosing the currently recessed porch and by extending the east wall where the porch is located by 3.5 feet. The side yard setback would be reduced from 26.9 feet to 23.4 to facilitate this proposal. Morgan applied to the board, by application dated October 23, 1989, for a variance from 4.6 of the Redding zoning regulations requiring a side yard setback of forty feet, and for a variance from 3.13 of those regulations to allow the addition to a nonconforming use that will decrease the side yard setback. The board granted the variance and the plaintiff appealed to the Superior Court.

In the trial court, the plaintiff argued (1) that the board was without authority to grant a variance where the regulations prohibit the expansion of a nonconformity, and (2) that Morgan did not show a legally cognizable hardship. The court sustained the plaintiff's appeal, finding that the board did not have the authority to grant the variance and that no legally cognizable hardship existed. Citing Grillo v. Zoning Board of Appeals, 4 Conn. App. 205, 208, 493 A.2d 275 (1985), the court held that there was no hardship because Morgan failed to demonstrate "that the application of the regulation to the property greatly destroys its value for any of the uses to which it could reasonably be put and [that] the regulation, as applied, bears so little relationship to the purpose of zoning that, as to particular premises, the regulation has a confiscatory or arbitrary effect."

The defendants first challenge the trial court's determination that the board did not have the authority to grant the variance. The plaintiff argues that the legislature's broad granting of power to local zoning boards of appeal was limited by the regulations promulgated by the local zoning commission regarding nonconforming uses.

General Statutes 8-6 (3) empowers a zoning board of appeals "to determine and vary the application of the zoning bylaws, ordinances or regulations in harmony with their general purpose . . . provided that the zoning regulations may specify the extent to which uses shall not be permitted by variance in districts where such uses are not otherwise allowed."

In Wells v. Zoning Board of Appeals, 180 Conn. 193, 196-98, 429 A.2d 467 (1980), and Johnny Cake, Inc. v. Zoning Board of Appeals, 180 Conn. 296, 301, 429 A.2d 883 (1980), our Supreme Court construed zoning regulations that prohibited certain uses also to prohibit the issuing of variances for these uses. The plaintiff argues that these cases require by implication that the zoning regulations must explicitly authorize the issuance of variances before the zoning board of appeals can grant a variance that would expand a nonconforming use. The plaintiff reasons that because the zoning regulations from which Morgan sought a variance do not explicitly authorize the board to issue variances, the rule from Wells and Johnny Cake, Inc., prohibits the board from varying these regulations. We do not agree.

To interpret Wells and Johnny Cake, Inc., as broadly as the plaintiff suggests would violate the plain meaning of 8-6. That statute grants broad powers to the zoning board of appeals and limits those powers only when the zoning commission passes a regulation explicitly limiting the issuance of variances.

Although the Supreme Court construed the zoning regulations in Wells and in Johnny Cake, Inc., to prohibit the respective zoning boards of appeals from issuing variances, the facts in this case make such a construction impossible. The town of Redding has a zoning regulation that delineates the zoning board of appeals' authority to grant variances. Section 6.6(b) of the Redding zoning regulations specifies that the zoning board of appeals shall have the power to "determine applications for variance . . . [but] shall not allow the creation, expansion, extension or intensification of non-residential uses in Residential Zones." In light of this regulation and General Statutes 8-6, we conclude that the board did have the authority to grant the variance sought by Morgan in this case.

The defendants' second claim is that a legally sufficient hardship existed on Morgan's property. The defendants argue that the trial court improperly reversed the board's decision to grant Morgan a variance because the trial court did not apply the proper standard. The trial court determined upon its review of the record that any difficulties suffered by Morgan did not constitute a legally recognized hardship. The trial court gave the following formulation of the test for the existence of a hardship: "Exceptional difficulty or undue hardship is established where a board could reasonably find that the application of the regulation to the property greatly destroys its value for any of the uses to which it could reasonably be put and where the regulation bears so little relationship to the purpose of zoning that, as to the particular premises, the regulation has a confiscatory or arbitrary effect." The trial court concluded that because the record is devoid of evidence that the property has little or no value because of the setback regulations, no hardship has been shown.

The defendants argue that the test applied by the trial court is overly restrictive and is not the proper test for establishing hardship in this case. We agree.

The test applied by the trial court was adopted from Grillo v. Zoning Board of Appeals, supra. This test is used in the extreme situation where the application of a regulation renders property practically worthless, and that loss of value alone amounts to a hardship. See Dolan v. Zoning Board of Appeals, 156 Conn. 426, 431, 242 A.2d 713 (1968). Although satisfying this test is a valid means of establishing a hardship, it is not exclusive.

A variance may be granted if the literal enforcement of a regulation causes exceptional difficulty or hardship because of some unusual characteristic of the property. General Statutes 8-6 (3); Belknap v. Zoning Board of Appeals, 155 Conn. 380, 383, 232 A.2d 922 (1967). To support the granting of a variance, a hardship must arise from a condition different in kind from that generally affecting properties in the same zoning district and must be imposed by conditions outside the property owner's control. See Whittaker v. Zoning Board of Appeals, 179 Conn. 650, 658, 427 A.2d 1346 (1980); Garibaldi v. Zoning Board of Appeals, 163 Conn. 235, 238, 303 A.2d 743 (1972).

The defendants argue that a hardship exists on Morgan's property because of the location of the well and the septic system, and because of the size of the lot. The placement of these improvements prevents Morgan from building an addition to her house anywhere except on the east side, which is prohibited by the setback requirement. These unique conditions make the setback regulation exceptionally burdensome and support the board's granting of the variance.

The trial court also found that any hardship that was present was personal to Morgan and, therefore, not legally cognizable. See Garibaldi v. Zoning Board of Appeals, supra, 240. We disagree.

The hardship claimed by the defendants arises from the configuration of Morgan's lot and the location of the well and the septic system. These conditions are not personal to Morgan and would exist no matter who owned the lot.

The trial court apparently believed that Morgan was claiming the circumstances regarding her advancing age as a hardship. It, therefore, found these circumstances to be personal and not capable of constituting a legally recognized hardship.

The plaintiff argues, as an alternative ground for affirming the trial court, that because the well and septic systems were installed by Morgan, any hardship they impose was self-created. We agree with the trial court that because the installation of these improvements predates the zoning regulations, the hardship created by their location cannot be considered self-created.


Summaries of

Stillman v. Zoning Board of Appeals

Appellate Court of Connecticut
Sep 3, 1991
25 Conn. App. 631 (Conn. App. Ct. 1991)

In Stillman, the defendant landowner sought a variance of the town of Redding's coverage and setback regulations in order to build an addition to her house, which the Zoning Board of Appeals of the Town of Redding granted.

Summary of this case from E&F Assocs., LLC v. Zoning Bd. of Appeals of the Town of Fairfield

zoning board of appeals properly granted variance from setback requirements when placement of well and septic system prevented applicant from building addition to house anywhere except in setback

Summary of this case from E&F Assocs., LLC v. Zoning Bd. of Appeals of the Town of Fairfield

In Stillman, there were permanent structures on an undersized but legally nonconforming lot that prevented the defendant from constructing the proposed addition at any location other than within the setback.

Summary of this case from Bloom v. Zoning Board of Appeals

In Stillman, however, the denial of the requested variance prevented the applicant from building any type of addition onto her previously existing home, which was situated on a nonconforming lot.

Summary of this case from Green Falls Associates, LLC v. Zoning Board of Appeals

In Stillman, the applicant homeowner sought a variance from the town of Redding's setback and coverage regulations in order to build an addition to her home.

Summary of this case from Jersey v. Zoning Board of Appeals

In Stillman, there were permanent structures on an undersized lot that prevented the defendant from constructing the proposed addition at any location other than within the setback.

Summary of this case from St. Luke's Dev. Corp. v. Bd. of Zoning

In Stillman v. Zoning Board of Appeals, 25 Conn.App. 631 (1991), the Appellate Court supported a finding of the municipal zoning board of appeals, concerning the existence of a hardship, thus reversing a determination that no hardship was present, as found by the trial judge.

Summary of this case from INGRAM v. WESTON ZBA

In Stillman v. Zoning Board of Appeals, 25 Conn.App. 631 (1991), the hardship consisted of the particular location of the well and septic system which limited the location of the addition for which the variance was sought.

Summary of this case from NELSON v. WESTPORT ZBA

In Stillman, there were permanent structures on an undersized but legally nonconforming lot that prevented the defendant from constructing the proposed addition at any location other than within the setback.

Summary of this case from PRISLEY v. DEEP RIVER ZBA

In Stillman v. Zoning Board of Appeals, 25 Conn.App. 631, 636 (1991), our Appellate Court held "To support the granting of a variance, a hardship must arise from a condition different in kind from that generally affecting properties in the same zoning district and must be imposed by conditions outside the property owner's control."

Summary of this case from RANSOM v. NEW MILFORD ZBA

In Stillman v. Zoning Board of Appeals, 25 Conn.App. 631, 596 A.2d 1 (1991), the Appellate Court upheld a zoning board of appeals decision granting a variance for the construction of an addition to a house, allowing an increase of an encroachment upon a side yard setback.

Summary of this case from Judelson v. Town of Madison Bd. of App.

In Stillman, the Appellate Court concluded that "[t]he hardship claimed by the defendants [arose] from the configuration of [the defendant's] lot and the location of the well and the septic system."

Summary of this case from Cody v. Town of New Cannan Zoning Board

In Stillman, the location of a septic system and well that forced the defendant to build an addition to her house in a particular direction, was deemed a "unique [condition that made] the setback regulation exceptionally burdensome and [supported] the board's granting of the variance."

Summary of this case from Cody v. Town of New Cannan Zoning Board

In Stillman, the property owner sought a variance in order to construct an addition that would encroach upon the setback area because the placement of a well and septic system on the subject property prevented construction of the desired addition anywhere else.

Summary of this case from WEBER v. TOWN OF RIDGEFIELD ZBA

In Stillman v. Zoning Board of Appeals, 25 Conn. App. 631, 636 (1991), the Appellate Court rejected the standard used by the trial court that unless the property "has little or no value because of the setback regulations, no hardship has been shown" as overly restricted.

Summary of this case from MacDonald v. Town of Waterford

In Stillman v. Zoning Board of Appeals, 25 Conn. App. 631, 596 A.2d 1, cert. denied, 220 Conn. 923, 598 A.2d 365 (1991), the property owner sought to expand the nonconformity of their home by constructing an addition, which would decrease the side-yard setback.

Summary of this case from ENGEN v. NEW CANAAN ZBA

In Stillman, the court held that the plaintiff, who requested a variance in order to build an addition, established hardship due to the configuration of the lot and the location of the well and septic system.

Summary of this case from PIETRUSKA v. MILFORD ZBA

In Stillman, the Appellate Court emphasized that the hardship arose from the configuration of the applicant's lot as well as the locations of the well and the septic system.

Summary of this case from REMESCH v. ANDOVER ZBA

In Stillman, the presence of a septic system and a well prevented expansion of an existing structure anywhere except within the setback area.

Summary of this case from LO v. NEW HAVEN ZBA

In Stillman, which involved a request for a setback variance, the owner of a legally nonconforming rectangular parcel sought to expand the first floor of a home, by adding a bathroom and a laundry room, within the side yard setback area.

Summary of this case from MAIORANO v. NEW HAVEN ZBA

In Stillman, the court held that the plaintiff, who requested a variance in order to build an addition, established hardship due to the configuration of the plaintiff's lot and the location of the well and septic system.

Summary of this case from JACOBSEN v. WOODBURY ZBA

In Stillman v. Zoning Board of Appeals, 25 Conn. App. 631, 636-37, 596 A.2d 1, cert. denied, 220 Conn. 923, 598 A.2d 923 (1991), the Appellate Court held that the unique conditions on the defendants' lot "make the setback regulation exceptionally burdensome and support the board's granting of the variance.

Summary of this case from Burke v. New Canaan Zoning Brd. of App.

In Stillman v. Zoning Board of Appeals, 25 Conn. App. 631, 636-37, 596 A.2d 1, cert. denied, 220 Conn. 923, 598 A.2d 923 (1991), the Appellate Court held that the unique conditions on the defendants' lot "make the setback regulation exceptionally burdensome and support the board's granting of the variance.

Summary of this case from Kelley v. Willington Zoning Board of Appeals

In Stillman, however, it was not merely the size of the lot that constituted the hardship, but also the location of a well and a septic system that constituted a hardship requiring a variation from the setback requirement.

Summary of this case from Allard v. Zoning Board of Appeals

In Stillman v. Zoning Board of Appeals, 25 Conn. App. 631, 637, 596 A.2d 1 (1991), the court held that an applicant, who requested a variance in order to build an addition, established hardship due to the configuration of the applicant's lot and the location of the well and septic system.

Summary of this case from Lacerenza v. Stamford Zoning Bd. of App.
Case details for

Stillman v. Zoning Board of Appeals

Case Details

Full title:MARY G. STILLMAN v. ZONING BOARD OF APPEALS OF THE TOWN OF REDDING ET AL

Court:Appellate Court of Connecticut

Date published: Sep 3, 1991

Citations

25 Conn. App. 631 (Conn. App. Ct. 1991)
596 A.2d 1

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