Bhargava v. Prince George's Cnty. Planning Bd.

CourtCourt of Special Appeals of Maryland
DecidedApril 1, 2025
Docket0659/23
StatusPublished

This text of Bhargava v. Prince George's Cnty. Planning Bd. (Bhargava v. Prince George's Cnty. Planning Bd.) is published on Counsel Stack Legal Research, covering Court of Special Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bhargava v. Prince George's Cnty. Planning Bd., (Md. Ct. App. 2025).

Opinion

Brij Bhargava v. Prince George’s County Planning Board, No. 0659, September Term, 2023. Opinion by Kehoe, S., J.

Background: The Prince George’s County Planning Department of the Maryland National Capital Park and Planning Commission approved of an application for a variance from the County’s tree conservation ordinance to permit the Prince George’s County Public Schools to remove eleven specimen trees to allow for the construction of new school. Citizen Appellants filed an appeal to the Prince George’s County Planning Board of the Maryland- National Capital Park and Planning Commission, which affirmed the variance. Appellants filed a petition for writ of administrative mandamus to the Circuit Court for Prince George’s County, which dismissed the petition because the issue was moot and because the Appellants had failed to show any right in the continued existence of the specimen trees.

Holdings: The Appellate Court has jurisdiction to consider an appeal of dismissal of a petition for writ of administrative mandamus because it was an appeal of the exercise of original jurisdiction by a circuit court.

Variances from forest conservation ordinances, which are authorized by Md. Code Ann., Nat. Res. (“NR”) § 5-1611 et seq. (2023 Repl.), are qualitatively different from zoning variances, which are authorized by Md. Code Ann., Land Use § 4-305.

The Appellants lacked standing to bring the appeal because they could not demonstrate a cognizable right in the trees that were subject to removal.

The matter was moot because the trees had been removed and the Appellants took no action to prevent their removal.

WOODS & FORESTS Variances under a forest conservation ordinance are distinct from variances under a zoning ordinance. Unlike variances from a zoning ordinance, which must account for the effect on surrounding properties, variances from forest conservation ordinances address the regulation of the State’s natural resources pursuant to Md. Code Ann., NR § 5-1611.

APPPEAL AND ERROR A trial court’s consideration of an administrative mandamus action is an exercise of original jurisdiction by the trial court over which an appeal may be taken to the Appellate Court. Md. Code Ann., Cts. & Jud. Proc. § 12-301.

STANDING Appellants lacked standing to pursue an appeal because variances under the Prince George’s County tree ordinance require an examination of the property itself. This requirement is different from zoning variances, which consider the relationship of the subject property to surrounding properties. MOOTNESS A matter is moot when there is no existing controversy from which the court can fashion a solution. Department of Human Services v. Roth, 398 Md. 137 (2007). In this case, the trees had been removed, and the Appellants had not taken any steps to block removal. Circuit Court for Prince George’s County Case No. CAL21-13945

REPORTED

IN THE APPELLATE COURT

OF MARYLAND

No. 659

September Term, 2023 ______________________________________

BRIJ BHARGAVA

v.

PRINCE GEORGE’S COUNTY PLANNING BOARD ______________________________________

Nazarian, Kehoe, S., Zarnoch, Robert A. (Senior Judge, Specially Assigned),

JJ. ______________________________________

Opinion by Kehoe, J. ______________________________________

Filed: April 1, 2025

Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic.

2025.04.01 15:22:12 -04'00' Gregory Hilton, Clerk Despite the Appellants’ efforts to frame this appeal as a zoning case, it is manifestly

not a zoning case. This matter is an appeal from a decision of the Circuit Court for Prince

George’s County dismissing a petition for administrative mandamus, regarding a decision

by the Prince George’s County Planning Board of the Maryland-National Capital Park and

Planning Commission (the “Board”), affirming the grant of a tree variance for the

construction of a K-8 public school on property owned by the Prince George’s County

Public Schools (“PGCPS”), 1 filed by the Appellants, Nancy Bhargava, Brij Bhargava,

Valencia Campbell, Brad Majors, and Derrick Southerland (“Appellants”). The circuit

court dismissed the case because it found that the request for administrative mandamus was

moot and that the Appellants lacked standing.

The case arises out of an application by the PGCPS for a variance from the County’s

Tree Conservation Ordinance (Prince George’s County Code (“County Code”), Article 25)

to remove eleven specimen trees 2 from a property to allow for the construction of a K-8

school. The Prince George’s County Planning Department of the Maryland-National

Capital Park and Planning Commission (the “Department”) approved the application for

In the record, PGCPS is referred to as the Board of Education of Prince George’s 1

County and Prince George’s County Public Schools. 2 Specimen trees are defined as:

Trees having a diameter at breast height of 30 inches or more; trees having 75% or more of the diameter at breast height of the current champion of that species; or a particularly impressive or unusual example of a species due to its size, shape, age or any other trait that epitomizes the character of the species. This definition includes all the United States, the State of Maryland and County, or municipality champion trees. See also County Code, Sec. 25-118(b)(65). the variance for the removal of ten specimen trees on May 17, 2021. The Department

approved a supplemental application to remove an additional specimen tree on August 18,

2021. The Appellants noted an appeal to the Board, which affirmed the approval by voice

vote on October 14, 2021. The Appellants filed a petition for administrative mandamus in

the Circuit Court for Prince George’s County, which the circuit court dismissed as moot.

The circuit court also determined that the Appellants did not “show possession of a specific

and clear legal, substantial right or any right at all to the continued existence of the

specimen trees.” For reasons set forth below, we affirm the decision of the circuit court.

The following issues have been condensed and presented for appeal: 3

I. Whether the Appellate Court has jurisdiction to consider an appeal of petition for administrative mandamus.

II. Whether the Circuit Court’s dismissal of the Appeal was legally correct.

I. Factual Background

In the 1960s, the PGCPS acquired an unimproved 29.78-acre parcel of land in the

Fort Washington area of Prince George’s County. The property remained vacant and

3 The issues presented by the Appellants are:

1. Whether the Prince George’s County Planning Board met the minimum requirements for articulating the facts found, the law applied, and the relationship between the two when it failed to issue a written decision.

2. Whether the Prince George’s County Planning Board erred legally when it determined that Section 25-119(d)(1)(A) did not require a finding of uniqueness and unwarranted hardship as those terms have been defined under Maryland’s variance jurisprudence.

2 3. Whether the record lacked substantial evidence to support the Prince George’s County Planning Board’s decision to affirm TCP2-007-2021, TCP2-007- 2021-01, and the associated variances.

4. Whether the Circuit Court for Prince George’s County erred legally when it dismissed Citizen-Appellants’ Petition for Judicial Review.

The issues presented by the PGCPS are:

1.

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Bhargava v. Prince George's Cnty. Planning Bd., Counsel Stack Legal Research, https://law.counselstack.com/opinion/bhargava-v-prince-georges-cnty-planning-bd-mdctspecapp-2025.