EMAC, L.L.C. v. Hanover County

89 Va. Cir. 292, 2014 Va. Cir. LEXIS 126
CourtHanover County Circuit Court
DecidedNovember 12, 2014
DocketCase No. CL14001503-00
StatusPublished

This text of 89 Va. Cir. 292 (EMAC, L.L.C. v. Hanover County) is published on Counsel Stack Legal Research, covering Hanover County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
EMAC, L.L.C. v. Hanover County, 89 Va. Cir. 292, 2014 Va. Cir. LEXIS 126 (Va. Super. Ct. 2014).

Opinion

By Judge J. Overton Harris

Before the Court is Defendants’ Demurrer. The parties were represented by their respective counsel at a hearing on September 30, 2014. The Court heard argument and took the matter under advisement. Following a thorough review of the pleadings and the law, the Court finds as follows.

I. Background

Accepting the factual allegations in Plaintiff’s Amended Complaint as true, the following facts are relevant to the demurrer. This case came before this Court as an appeal and challenge of the decision of the Board of Supervisors of Hanover County (“the Board”) on May 28, 2014, to deny EMAC’s application for an extension of its Conditional Use Permit (“CUP”) for a destination commerce sign on its property.

EMAC’s Amended Complaint, filed October 9, 2014, makes the following assertions: (1) the Board violated Dillon’s Rule by exceeding its express and necessarily implied authority by imposing a requirement that EMAC enter into an agreement with Craig Realty and others as a condition of the extension; (2) the denial of the extension was arbitrary, capricious, [293]*293and in violation of Virginia law; (3) EMAC is entitled to damages for deprivation of its substantive and procedural due process rights; (4) EMAC is entitled to a declaratory judgment for violations of the Due Process Clause of the Virginia and Federal Constitutions; (5) EMAC is entitled to damages for the violation of its rights under the Equal Protection Clause of the Fourteenth Amendment; (6) EMAC is entitled to a declaratory judgment for violations of the Equal Protection Clause of the Fourteenth Amendment; (7) the denial of the extension constitutes a taking of EMAC’s property without just compensation in violation of the Fifth and Fourteenth Amendments to the U.S. Constitution and Article I, Section 11, of the Constitution of Virginia; and (8) the Board denied EMAC its vested rights in violation of Va. Code § 15.2-2307. Defendants filed their Demurrer and Motion to Dismiss EMAC’s Amended Complaint on October 20, 2014.

II. Standard of Review

A demurrer may be employed to strike a pleading that does not state a cause of action or fails to state facts upon which relief may be granted. Virginia Code § 8.01-273. A demurrer admits the factual pleadings to be true and accepts any reasonable factual inferences fairly and justly drawn from them. Fox v. Custis, 236 Va. 69, 71, 372 S.E.2d 373, 374 (1988). “A court may examine not only the substantive allegations of the pleading attached, but also any accompanying exhibit mentioned in the pleading.” CaterCorp, Inc. v. Catering Concepts, Inc., 246 Va. 22, 24, 431 S.E.2d 277, 278 (1993).

The demurrer does not, however, admit the correctness of the pleading’s conclusions of law. Fox, 236 Va. at 69. Upon examination and consideration of the exhibits, the Court “may ignore a party’s factual allegations contradicted by the terms of authentic, unambiguous documents that properly are a part of the pleadings.” Ward’s Equip., Inc. v. New Holland N. Am., 254 Va. 379, 382, 493 S.E.2d 516, 518 (1997); see Dodge v. Randolph-Macon Women’s College, 276 Va. 1, 5, 661 S.E.2d 801, 803 (2008).

III. Analysis

In Virginia, legislative action is presumed reasonable, and the burden rests on the party attacking it to establish that it is unreasonable. Concerned Taxpayers v. Brunswick, 249 Va. 320, 327 (1995). In the exercise of its police powers, the legislative branch of a local government has broad discretion in the adoption of zoning regulations. Its action is presumed to be valid and will not be disturbed by a court absent clear proof that the action is unreasonable, arbitrary, and bears no reasonable relation to the public health, safety, morals, or general welfare. City Council of Virginia Beach v. Harrell, 236 Va. 99, 101, 372 S.E.2d 139, 141 (1988).

[294]*294When, however, the presumption of validity is challenged by probative evidence of unreasonableness, the enactment cannot be sustained unless the legislative body meets the challenge with some evidence of reasonableness. Harrell, 236 Va. at 102. The governing body need not prove the reasonableness of its action by a preponderance of the evidence, but must only produce evidence sufficient to make the question “fairly debatable.” Fairfax County v. Southland Corp., 224 Va. 514, 522-23, 297 S.E.2d 718, 722 (1982). If the reasonableness of the enactment is fairly debatable, a court will not substitute its judgment for that of the legislative body, and the legislation.will be sustained. Harrell, 236 Va. at 101.

The standards of judicial review applicable to zoning enactments also apply to actions taken by a local governing body on an application for a conditional use permit. City of Richmond v. Randall, 215 Va. 506, 511, 211 S.E.2d 56, 60 (1975); see also Southland Corp., 224 Va. at 522, 297 S.E.2d at 722.

The presumption of legislative validity attaches not only to zoning ordinances adopted by legislative bodies, but also to actions on applications for special use permits where legislative bodies are empowered by law to take such actions. And here, too, the linchpin of the presumption is reasonableness. When a landowner whose special use permit has been denied shows that the existing zoning ordinance, as applied to his land, is invalid, and that the use he requested is reasonable, he has made a primafacie showing that the legislative action denying his permit was unreasonable. The burden then shifts to the legislative body to produce evidence showing that the denial was reasonable. If evidence of reasonableness is sufficient to make the question fairly debatable, the legislative denial must be sustained. If not, it cannot be sustained.

Randall, 215 Va. at 511, 211 S.E.2d at 60. Thus, to make a prima facie showing that the denial of a conditional use permit was unreasonable, a landowner must show not only that the use he requests is reasonable but that the existing zoning ordinance, as applied to his land, is unreasonable. Harrell, 236 Va. at 102; see also Board of Supervisors v. International Funeral Services, Inc., 221 Va. 840, 843, 275 S.E.2d 586, 588 (1981) (“When a landowner has been denied rezoning and he challenges the denial, his threshold burden of proof requires a clear demonstration that the existing zoning classification is no longer reasonable or appropriate.”).

The Court accepts as true all facts from the pleadings, as well as any reasonable factual inferences fairly and justly drawn from them. The Court also assumes that the proposed use of CUP 2-12 by EMAC is reasonable.

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Bluebook (online)
89 Va. Cir. 292, 2014 Va. Cir. LEXIS 126, Counsel Stack Legal Research, https://law.counselstack.com/opinion/emac-llc-v-hanover-county-vacchanover-2014.