5154 Hamilton South Property, LLC v. Hamilton Twp. ZHB

CourtCommonwealth Court of Pennsylvania
DecidedJuly 2, 2025
Docket17 C.D. 2024
StatusUnpublished

This text of 5154 Hamilton South Property, LLC v. Hamilton Twp. ZHB (5154 Hamilton South Property, LLC v. Hamilton Twp. ZHB) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
5154 Hamilton South Property, LLC v. Hamilton Twp. ZHB, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

5154 Hamilton South Property, LLC, : Appellant : : v. : No. 17 C.D. 2024 : Hamilton Township Zoning Hearing : Argued: December 9, 2024 Board, Saylors Lake Fishing : Association, and Hamilton Township : Board of Supervisors :

BEFORE: HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE MATTHEW S. WOLF, Judge HONORABLE BONNIE BRIGANCE LEADBETTER, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE McCULLOUGH FILED: July 2, 2025

5154 Hamilton South Property, LLC (Property Owner) appeals from the December 5, 2023 order of the Court of Common Pleas of Monroe County (trial court), which affirmed the September 6, 2023 decision and order of the Hamilton Township Zoning Hearing Board (Board). In its decision the Board denied Property Owner’s requests for rear dimensional setback variances sought as part of its proposal to enlarge a deck attached to the Lakeside Restaurant at Saylors Lake in Hamilton Township (Township). After careful review, we affirm the trial court. I. BACKGROUND Property Owner is the owner of the Lakeside Restaurant (Restaurant) at Saylors Lake in the Township. (Board (Bd.) Finding of Fact (F.F.) No. 2.) Under the Township Zoning Ordinance (Ordinance),1 the Restaurant is in a C-1 zoning district (C-1 Zone) and is a permitted use. (Bd. Op. at 1.) In 2002, a former owner of the Restaurant applied for a zoning permit to construct a deck between the Restaurant and the Saylors Lake waterline (the “2002 Deck”). The application contained a hand-drawn sketch of the Restaurant and Deck but presented no demarcation of the rear yard zoning setback. Despite this lack of required information, the Township Zoning Officer erroneously issued a permit for construction of the Deck, not realizing that the Deck violated the Ordinance’s 20- foot rear yard setback requirement of the C-1 Zone.2 Property Owner purchased the Restaurant on July 21, 2021. On September 22, 2022, Property Owner applied to the Board for 3 dimensional rear setback variances from the 20-foot rear yard setback line required for structures in the C-1 Zone. Property Owner sought the variances to enlarge the 2002 Deck. The proposed expansion was to include the following three areas: 1. Dining Area Expansion. This proposed [D]eck expansion, located directly behind the main [R]estaurant building[,] is 11 feet 8 ¼ inches in depth by 72 feet (+ or -) in length. This [D]eck expansion extends the [2022 Deck] as marked on the plan. The proposed [D]eck expansion encroaches no [farther]

1 Hamilton Township, Monroe County, Pa., Zoning Ordinance (1985).

2 The 2002 Deck was constructed 26 years after the Township adopted its Ordinance on August 30, 1976. (Bd. F.F. Nos. 8-9.)

2 onto the rear property line than the existing exterior [D]eck.

2. Corner Infill Deck. The second expanded space is designated “corner infill [D]eck” measuring 17 feet in length adjoining the existing walls of the existing exterior dining [D]eck. The “corner infill [D]eck” proposes a curvilinear edge encroaching no closer to the water edge/rear property line than the existing exterior dining [D]eck.

3. Exterior Dining/Event Deck. The third and final proposed expanded area is designated measuring 16 feet by 80 feet. To be located between the main parking area and the (area) of Saylors Lake “edge of water.”

(Bd. Op. at 1-2.) The proposed expansion of the Restaurant building would extend beyond the rear setback line established by the Ordinance. (Tr. Ct. Op. at 3.) A. Proceedings Before the Board3 The Board addressed Property Owner’s request for variances during three meetings held on January 26, 2023, March 14, 2023, and April 17, 2023. On April 17, 2023, Property Owner amended its application so that, among other things, the application depicted the rear setback line. (Bd. F.F. No. 14.) The amended plan reduced the depth of the 72-foot southern addition to 5 feet, 5/8 inches, which would become part of the indoor dining area. This addition would

3 The Township exercised its right to be a party to the proceeding pursuant to Section 908(3) of the Pennsylvania Municipalities Planning Code (MPC), Act of July 31, 1968, P.L. 805, as amended, 53 P.S. § 10908(3). In addition, a couple who own property contiguous to and overlooking the Property also requested and were granted party status in the proceeding, (Bd. F.F. No. 4), as was the Saylors Lake Fishing Association (SLFA).

3 be entirely in violation of the 20-foot rear setback line of the Ordinance. (Tr. Ct. Op. at 4.) Property Owner contended before the Board that the Restaurant was a non-conforming structure which could be expanded in compliance with Article VII of the Ordinance governing “Non-Conforming Lots, Uses and Structures.” (Bd. F.F. No 7.) Article VII of the Ordinance provides rules that apply to lots, uses, or structures that existed lawfully “before the effective date of adoption of the Ordinance” in 1976 or in the case of a non-conforming structure is “legally established by the [] Board through the granting of a variance.” (Property Owner’s Reproduced Record (R.R.) at 221a.) Property Owner stated that “the proposed extensions of [preexisting] non-conforming setback lines are necessary for the continued reasonable use of the [P]roperty and within the guidelines [of] Article VII applicable to non-conforming structures.” (emphasis in original) (Bd. Op. at 2.) After the conclusion of the hearings, the Board issued an opinion determining that a plain reading of the definition of the term “non-conforming structure” set forth in Section 201.4 of the Ordinance demonstrated that Article VII of the Ordinance does not apply to this matter. (Bd. Conclusion of Law Nos. 10- 14.) Section 201.4 defines a non-conforming structure, in pertinent part, as: Non-Conforming Structure: A building or structure which does not conform to the zoning district regulations in Schedule II and which is legally existing at the time of enactment of this Ordinance. . . .”

(Original Record (O.R.) at 675.)

4 The Board also relied upon Section 704 of the Ordinance in determining that the Property did not qualify as a “non-conforming structure.”4 It provides, in pertinent part: Section 704: Non-conforming Structure A non-conforming structure is any building or structure which does not conform to the zoning district regulations established in Schedule II, and which is legally existing at the time of enactment of this Ordinance or is legally established by the []Board through the granting of a variance.

(R.R. at 221a.) The Board explained that because the 2002 Deck was first constructed in 2002, well after the August 30, 1976 date of adoption of the Ordinance, it did not meet the Ordinance definitions of a non-conforming structure. Therefore, Article VII of the Ordinance provision, upon which Property Owner relies, is not relevant to its variance requests. (Bd. Conclusion of Law Nos. 10-14.) During the hearings, the Township advised the Board that the Township erroneously issued a permit for the original construction of the 2002 Deck and that the Township would not contest the legality of the original Deck because the Deck was constructed in reliance on the erroneously issued 2002 permit. The Township also informed the Board that it would not contest an application by Property Owner to obtain a variance by estoppel or by collateral estoppel with regard to the existing 2002 Deck because the Township would be estopped from contending that the 2002 Deck is an illegal structure. (Bd. Op. at 8- 11.)5

4 It is unclear why the Ordinance appears to have two different definitions of the term “Non-conforming Structure.” 5 The Board explained that “[v]ariance by estoppel, applies when a property owner, or someone with an interest in property, has maintained a use of property contrary to the zoning laws (Footnote continued on next page…)

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5154 Hamilton South Property, LLC v. Hamilton Twp. ZHB, Counsel Stack Legal Research, https://law.counselstack.com/opinion/5154-hamilton-south-property-llc-v-hamilton-twp-zhb-pacommwct-2025.