City of Norwich v. Norwalk Wilbert Vault Co.

544 A.2d 152, 208 Conn. 1, 1988 Conn. LEXIS 160
CourtSupreme Court of Connecticut
DecidedJune 21, 1988
Docket13200
StatusPublished
Cited by64 cases

This text of 544 A.2d 152 (City of Norwich v. Norwalk Wilbert Vault Co.) is published on Counsel Stack Legal Research, covering Supreme Court of Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Norwich v. Norwalk Wilbert Vault Co., 544 A.2d 152, 208 Conn. 1, 1988 Conn. LEXIS 160 (Colo. 1988).

Opinion

Glass, J.

The named plaintiff,1 the city of Norwich, instituted an action seeking to enjoin the defendant, Norwalk Wilbert Vault Company, Inc., from operating a trucking terminal on its property located in Norwich, claiming that the defendant was in violation of Norwich zoning ordinance because it did not file a site plan with the commission on the city plan (commission) prior to engaging in this use of the property. The trial court rendered judgment for the plaintiff enjoining the defendant from using its property as a trucking terminal. The defendant appealed to the Appellate Court claiming, inter alia, that the ordinance delegating to the commission the authority to approve or disapprove site plans was an impermissible delegation of a zoning function. The Appellate Court held that this claim was not properly before the court because the defendant had not been aggrieved by the ordinance it challenged, as the defendant had not sought to obtain site plan approval under the Norwich zoning ordinances.

[3]*3We granted certification limited to the issue as to whether, in an action by a city to enjoin certain activities of a landowner as violative of a zoning ordinance, the defendant landowner may attack the validity of the ordinance without first having attempted to secure such administrative relief as may be available under the ordinance. The plaintiff filed a preliminary statement of alternate grounds of affirmance, which presents the additional issue of whether, assuming that the defendant can challenge in this action the delegation of site plan review authority to the commission, that delegation was proper and constitutional under the city charter.

The underlying facts are fully set forth in Norwich v. Norwalk Wilbert Vault Co., 11 Conn. App. 332, 527 A.2d 716 (1987). The defendant operated a concrete manufacturing business on its property in Norwich, which was a conforming use in an area which was classified as a heavy industrial zone. In 1982, the defendant began renting space to various trucking companies that used the property as a trucking terminal. The heavy industrial zone permits trucking terminals. Under § 10.2.2 of the Norwich zoning ordinances, “[a]ll uses permitted in [the heavy industrial zone] shall be subject to site plan approval by the commission in accordance with the provisions of Chapter 17, hereof.” Chapter 17 of the Norwich zoning ordinances provides criteria for a site plan approval, and sets forth specific factors to be considered when a heavy industrial zone borders a residential zone. The trial court found that the use of the defendant’s property as a trucking terminal was an increased use of the property, and therefore, that site plan approval was needed. Because the defendant had not sought site plan approval prior to engaging in the increased use of the property, the trial court issued an injunction enjoining the defendant from using the premises as a trucking terminal. The Appellate Court [4]*4upheld the decision of the trial court on the ground that the defendant had not exhausted the available administrative remedies and therefore did not reach the issue of delegation of authority.

I

The Appellate Court held that the defendant’s claim, that the ordinance delegating the authority to the commission to approve or disapprove site plans was an impermissible delegation of a zoning function, was not properly before the court. The court reasoned that “[t]he defendant in this case has not been aggrieved by the ordinance it challenges. . . . Until the commission on the city plan functions as contemplated by the ordinances, it cannot possibly be said that the defendant has been denied due process by that ordinance. . . . If the defendant applies for and is denied site plan approval under the ordinance, it may then challenge, in a declaratory judgment action, the constitutionality of the ordinance.” Norwich v. Norwalk Wilbert Vault Co., supra, 337-38. We disagree with the holding of the Appellate Court.

It is well settled that a jurisdictional prerequisite to seeking relief in a court of law is that all available administrative remedies must have been exhausted. Concerned Citizens of Sterling v. Sterling, 204 Conn 551, 556, 529 A.2d 666 (1987); Cummings v. Tripp, 204 Conn. 67, 75, 527 A.2d 1230 (1987); Doe v. Heintz, 204 Conn. 17, 34, 526 A.2d 1318 (1987). We have held, however, that under limited circumstances, there are exceptions to this principle. One such exception is that where the available relief is inadequate or futile, the administrative process may be bypassed. Greenwich v. Liquor Control Commission, 191 Conn. 528, 541, 469 A.2d 382 (1983); Sullivan v. State, 189 Conn. 550, 553-54, 457 A.2d 304 (1983); Kosinski v. Lawlor, 177 Conn. 420, 425, 418 A.2d 66 (1979); Bianco v. Darien, 157 Conn. [5]*5548, 554-55, 254 A.2d 898 (1969). In LaCroix v. Board of Education, 199 Conn. 70, 79 n.7, 505 A.2d 1233 (1986), we noted that “[e]xhaustion of administrative remedies is generally not required when the challenge is to the constitutionality of the statute or regulation under which the board or agency operates, rather than to the actions of the board or agency. Conto v. Zoning Commission, 186 Conn. 106, 115, 439 A.2d 441 (1982); General Dynamics Corporation v. Groton, 184 Conn. 483, 490, 440 A.2d 185 (1981); Friedson v. Westport, 181 Conn. 230, 233, 435 A.2d 17 (1980).” Generally, such challenges have been instituted by a plaintiff in a declaratory judgment action. Bierman v. Planning & Zoning Commission, 185 Conn. 135, 440 A.2d 882 (1981); Bencivenga v. Milford, 183 Conn. 168, 438 A.2d 1174 (1981).

Today we apply this exception to the exhaustion principle to a case in which a defendant challenges the constitutional validity of a municipal ordinance in an action to enforce its provisions against him. This exception has gained acceptance by a number of state courts that have specifically considered this issue. The seminal case is Lake v. MacNeal, 24 Ill. 2d 253, 181 N.E.2d 85 (1962), where the court held that the exhaustion principle does not apply to an action brought by a local government to enforce its own ordinances. The court stated that “there is . . . the sound principle, based upon the assumption that one may not be held civilly or criminally liable for violating an invalid ordinance, that a proceeding for the violation of a municipal regulation is subject to any defense which will exonerate the defendant from liability, including a defense of the invalidity of the ordinance.” (Emphasis added.) Id., 260.

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Bluebook (online)
544 A.2d 152, 208 Conn. 1, 1988 Conn. LEXIS 160, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-norwich-v-norwalk-wilbert-vault-co-conn-1988.