Downing v. Knox County, Tennessee

CourtDistrict Court, E.D. Tennessee
DecidedJune 12, 2025
Docket3:23-cv-00300
StatusUnknown

This text of Downing v. Knox County, Tennessee (Downing v. Knox County, Tennessee) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Downing v. Knox County, Tennessee, (E.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE

SETH DOWNING, ) ) Plaintiff, ) Case No. 3:23-cv-300 ) v. ) Judge Atchley ) SERGHEY BOTEZAT & KNOX COUNTY, ) Magistrate Judge Poplin TENNESSEE, ) ) Defendants. )

MEMORANDUM OPINION AND ORDER Before the Court are Defendant/Cross-Defendant Knox County, Tennessee, and Defendant/Cross-Plaintiff Serghey Botezat’s Joint Motion for Partial Summary Judgment [Doc. 41],1 Botezat’s Motion for Partial Summary Judgment [Doc. 42], Botezat’s Motion for Summary Judgment [Doc. 43], Plaintiff/Counter-Defendant Seth Downing’s Motion for Summary Judgment [Doc. 46], Knox County’s Motion for Summary Judgment [Doc. 49], Downing’s Motion to Accept Late-Filed Answer [Doc. 53], and the parties’ Joint Motion to Stay [Doc. 66].2 For the following reasons, Botezat’s Motion for Summary Judgment [Doc. 43] is GRANTED, Downing’s Motion for Summary Judgment [Doc. 46] is DENIED, and Knox County’s Motion for Summary Judgment [Doc. 49] is GRANTED IN PART and DENIED IN PART. The Motions for Partial Summary

1 This Motion is also purportedly brought on behalf of “Defendants Knox County Board of Zoning Appeals (‘BZA’) [and] Knox County Planning Commission (‘Planning Commission’)[.]” [Doc. 41 at 1]. Neither the Knox County Board of Zoning Appeals nor the Knox County Planning Commission, however, are named as defendants in either the Amended Complaint [Doc. 24] or the Cross Complaint [Doc. 26 at 10–14]. Accordingly, the Court construes the Motion as being brought on behalf of only Knox County and Botezat.

2 This Motion is purportedly brought on behalf of the Knox County Board of Zoning Appeals and the Knox County Planning Commission in addition to Downing, Botezat, and Knox County. [Doc. 66 at 1]. Consistent with the Court’s decision regarding the Joint Motion for Partial Summary Judgment, see supra note 1, the Court will construe this motion as being brought on behalf of only Downing, Botezat, and Knox County. Judgment [Docs. 41–42], the Motion to Accept Late-Filed Answer [Doc. 53], and the Joint Motion to Stay [Doc. 66] are each DENIED AS MOOT. I. BACKGROUND This case concerns whether Seth Downing has the right to appeal a decision made by the Knoxville-Knox County Planning Commission (“Planning Commission”) to the Knox County

Board of Zoning Appeals (“BZA”) and whether the deprivation of that appeal violated his constitutional rights. Downing and Botezat own abutting real property in Knox County, Tennessee.3 [Doc. 47-3 at ¶¶ 2–3]. Downing uses his property as a private residence whereas Botezat wants to use his property for a 32-unit multi-dwelling development. [Id. at ¶ 2; Doc. 24 at ¶ 20; Doc. 25 at ¶ 20; Doc. 26 at ¶ 20]. To that end, Botezat sought approval of his development plan from the Planning Commission. [Doc. 24 at ¶ 20; Doc. 25 at ¶ 20; Doc. 26 at ¶ 20]. Downing objected to Botezat’s development plan, but the Planning Commission nevertheless approved it. [Doc. 47-3 at ¶¶ 4–5, 7; Doc. 47-5 at 21]. Downing then timely appealed the Planning Commission’s decision to the

BZA pursuant to Section 6.50.08 of the Knox County Zoning Ordinance. [Doc. 47-6 at ¶ 14]. Section 6.50.08 states in full: Appeal of development plans. In any Zone in which a “development plan” or “plan for development” must be approved by the planning commission prior to the construction or alteration of any building or development, any person, firm or corporation aggrieved by the decision of the planning commission regarding such development shall follow the following procedure for appeals:

(a) The aggrieved person or entity may file an appeal either to the Board of Zoning Appeals or to a court of competent jurisdiction within thirty (30) days of the decision being appealed.

(b) The Applicant for the development plan being challenged may opt out of the BZA appeal by sending, by certified mail, a notice of demand to have

3 Specifically, Downing owns the property located at 7201 Ball Camp Pike, Knoxville, TN, 37931, and Botezat owns the property located at 0 Ball Camp Pike, Knoxville, TN, 37931. [Doc. 47-3 at ¶¶ 2–3]. the matter heard by a court of competent jurisdiction to the Knox County Law Director’s Office, with a copy of said notice sent by certified mail to the address of the aggrieved appellant(s), within fifteen (15) days of the filing of the BZA appeal.

(c) In the event that such notice is filed with the Law Director’s Office, the appellant shall file the appeal with a court of competent jurisdiction within thirty (30) days of the notice having been mailed.

KNOX COUNTY, TENN., ZONING ORDINANCE § 6.50.08 (2025) (emphasis in original).4 In response, Botezat exercised his right under Section 6.50.08(b) to opt out of the BZA appeal and require Downing to appeal, if at all, to a Tennessee court of competent jurisdiction.5 [Doc. 47-4 at ¶ 8]. The effect of Botezat’s decision was significant. While the BZA would have reviewed the development plan de novo, judicial review of the development plan would be limited to whether the Planning Commission “acted illegally, arbitrarily, fraudulently, or in excess of its jurisdiction.” Venture Holdings, LLC v. Metro. Gov’t of Nashville & Davidson Cnty., 585 S.W.3d 409, 416 (Tenn. Ct. App. 2019). This lawsuit followed. [Doc. 1]. Downing claims that Knox County and Botezat violated his due process, equal protection, and First Amendment rights by depriving him of his ability to pursue a BZA appeal. [See generally Doc. 24]. He asks the Court to declare Sections 6.50.08(b) and (c) of the Knox County Zoning Ordinance (i.e., the provisions addressing a developer’s ability to opt out of a BZA appeal) unconstitutional and enjoin the County from enforcing them. [Id. at ¶¶ 99–103]. He also asks the Court to require Knox County to place his appeal back on the BZA’s agenda and to award him damages. [Id. at ¶¶ 104–05].

4 The Code of Knox County—including the Knox County Zoning Ordinance—can be found at the following link: https://library.municode.com/tn/knox_county/codes/code_of_ordinances?nodeId=COKNCOTE.

5 Downing has petitioned the Tennessee courts to review the Planning Commission’s decision. As this state case does not affect the resolution of the motions currently before the Court [see Doc. 23 at 3–10], it is not discussed further. Botezat responded to these claims with one of his own. [See Doc. 26 at 10–14]. He filed a Cross-Complaint alleging that Tennessee law does not authorize the BZA to hear appeals concerning the Planning Commission’s approval of development plans. [Id.]. He seeks a declaration to the same effect and an injunction preventing Knox County from enforcing Section 6.50.08 against him to the extent it purports to grant the BZA appellate jurisdiction over the

Planning Commission’s approval of development plans. [Id.]. He also seeks a related injunction preventing Knox County from enforcing Section 6.60.03(C) of the Knox County Zoning Ordinance which states: Powers of the board of zoning appeals. …

(C) To hear and decide in accordance with the provisions of article 4, “Supplementary regulations,” section 2, “Development standards for uses permitted on review,” and article 6, “Administration, enforcement and interpretation,” section 6.50, “Procedure for authorizing uses permitted on review,” of this ordinance, appeals from the planning commission of decisions regarding use-on-reviews.

KNOX COUNTY, TENN., ZONING ORDINANCE § 6.60.03(C) (2025) (emphasis in original). Now, the parties have filed five motions for summary judgment, each of which is ripe for review. Downing filed a single summary judgment motion wherein he argues that he should prevail on his constitutional claims as a matter of law. [Doc. 46]. Knox County, on the other hand, filed a summary judgment motion arguing the contrary. [Doc. 49].

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Bluebook (online)
Downing v. Knox County, Tennessee, Counsel Stack Legal Research, https://law.counselstack.com/opinion/downing-v-knox-county-tennessee-tned-2025.