Erichsen v. City of Norfolk

54 Va. Cir. 392, 2001 Va. Cir. LEXIS 191
CourtNorfolk County Circuit Court
DecidedJanuary 24, 2001
DocketCase No. (Chancery) C00-2018
StatusPublished

This text of 54 Va. Cir. 392 (Erichsen v. City of Norfolk) is published on Counsel Stack Legal Research, covering Norfolk County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Erichsen v. City of Norfolk, 54 Va. Cir. 392, 2001 Va. Cir. LEXIS 191 (Va. Super. Ct. 2001).

Opinion

BY JUDGE CHARLES E. POSTON

The Court grants die Defendants’ motion to strike die Plaintiffs’ evidence. Accordingly, this appeal taken pursuant to Virginia Code § 15.2-2006 and motion for declaratory judgment pursuant to Virginia Code § 8.01-184 are dismissed with prejudice. This case concerns an ordinance adopted by City Council on August 29,2000, closing a portion of Pretty Lake Avenue between 8th and 9th Bay Streets. In accord with familiar principles, the Court will consider the evidence in the light most favorable to the Plaintiffs.

Pretty Lake Avenue between 8th and 9th Bay Streets is an unimproved “paper” street. Although some property owners whose lots adjoin this street use it at times for ingress and egress, there is another means of access to those lots. The Plaintiffs have pedestrian access to their property from 8th Bay Street across Pretty Lake Avenue, although a more facile pedestrian access and limited vehicular access is available from 9th Bay Street over that portion of Pretty Lake Avenue which has been closed by City Council.

The defendant, Edward A. Clark, III, applied for the street closure to facilitate the real estate development he was planning for the area. Clark had built single family houses in neighboring developments. Closing the portion [393]*393of Pretty Lake Avenue from 9th Bay Street westward would, he thought, enable him to build additional houses. Clark’s development activities were consistent with the City’s plan for developing that area.

Clark’s application was referred to the City Planning Department, which studied it and recommended approval to the City Planning Commission. The Commission, in turn, held public hearings after giving notice to those concerned and forwarded the application to City Council with a recommendation for approval. It is important to note that consideration of a street closing application is not required by statute to be considered by the Planning Commission before City Council acts. The City Council caused the required notices to be given, held its own public hearing, and approved the application.

The Plaintiifs challenge the validity of the ordinance, on three grounds. Those grounds are stated in their Amended Bill of Complaint1 as follows:

1. The ordinance is illegal and unconstitutional because it was enacted solely to benefit private interests and not the interest of the public in general.

2. [The ordinance is] illegal and unconstitutional because the enactment of the ordinance deprives the plaintiffs of a valuable properly right, namely the right of reasonable access to their property without due process of law and without providing them with adequate compensation.

3. [T]he adoption of the ordinance violates the City’s own policies in reference to vacating streets and/or closing same and the action of the City Council in adopting said ordinance is arbitrary and capricious and therefore must be set aside.

Analysis of this matter begins with a Virginia Code § 15.2-2006, which provides authority for closing public rights of way, including streets, and requires notification of “land owners affected thereby, along the public right-of-way proposed to be altered or vacated.” All parties stipulated at trial that the required notice had been given.2 City Council held a public hearing, and [394]*394on August 29,2000, adopted an ordinance closing the portion of Pretty Lake Avenue in question. In the ordinance City Council found that: .

[S]aid portions of streets are not needed for public use and travel and should be closed, vacated and discontinued____

The Supreme Court has left no room for anyone to doubt that City Council has authority to close streets within its boundaries:

Streets are public highways, and hence the legislature has supreme control over diem, to open, improve, repair, or to vacate them, but this authority may be delegated to municipalities, and when so delegated may be exercised by the municipalities to the full extent of the power conferred.

City of Lynchburg v. Peters, 145 Va. 1, 9, 133 S.E. 674, 677 (1926) (internal citations omitted).

Indeed, the power to open and close streets is so essential to local government that the power is said to have been granted in a general welfare clause in a general statute relating to cities. Id. at 13, 133 S.E. at 678 (quoting with approval Commonwealth v. Illinois Cent. RR., 138 Ky. 749, 129 N.W. 96 (1910)). The authority to close streets, however, is not without limitation. When a municipality closes a street, the exercise of the power must be for the public welfare and not for the benefit of private interests. Peters, 145 Va. at 13, 133 S.E. at 678.

The closure of streets by a municipality is a legislative function, and the courts are loath to interfere with the exercise of legislative prerogatives. As the Supreme Court has taught:

When the power to vacate or close streets has been delegated to a municipality, in the absence of a showing that the closure was for solely private benefit, or that it was the result of collusion or fraud, it is the exercise of a political or legislative function which the courts will not review.

Id. This reluctance to interfere with the proper exercise of power by a coordinate branch of government is not easily overcome:

[395]*395There exists, however, a presumption favoring the validity of municipal ordinances and the presumption governs unless it is overcome by unreasonableness apparent on the face of the ordinance or by extrinsic evidence which clearly establishes the unreasonableness.

Kisley v. City of Falls Church, 212 Va. 693, 697, 187 S.E.2d 168, 171 (1972) (citing National Linen Service Corp. v. City of Norfolk, 196 Va. 277, 279, 83 S.E.2d 401, 403 (1954)). In the case sub judice, the ordinance is clearly reasonable on its face. Invalidity, then, if shown, must be demonstrated by extrinsic evidence.

While courts have used various words to describe the standard of proof required to justify interfering with a legislative action, the standard is that of clear and convincing evidence.

State legislatures and city councils, who deal with the situation from a practical standpoint, are better qualified than the courts to determine the necessity, character, and degree of regulation ... and their conclusions should not be disturbed by the courts unless clearly arbitrary and unreasonable.

Martin v. City of Danville, 148 Va. 247, 248-49, 138 S.E. 629 (1927). The Supreme Court more particularly defined the standard of proof in Sheek v. City of Newport News, 214 Va. 288, 290, 199 S.E.2d 519, 521 (1973):

Unless clear and convincing proof demonstrates that an ordinance is arbitrary and unreasonable, the ordinance must be upheld.

Id. (emphasis added). Further, the Supreme Court has held that if the question of reasonableness is fairly debatable, the ordinance will be upheld.

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Related

National Linen Service Corp. v. City of Norfolk
83 S.E.2d 401 (Supreme Court of Virginia, 1954)
Kisley v. City of Falls Church
187 S.E.2d 168 (Supreme Court of Virginia, 1972)
Town of Narrows v. Clear-View Cable TV. Inc.
315 S.E.2d 835 (Supreme Court of Virginia, 1984)
Sheek v. City of Newport News
199 S.E.2d 519 (Supreme Court of Virginia, 1973)
McLean v. News Publishing Co.
129 N.W. 93 (North Dakota Supreme Court, 1910)
City of Lynchburg v. Peters
133 S.E. 674 (Supreme Court of Virginia, 1926)
Martin v. City of Danville
138 S.E. 629 (Supreme Court of Virginia, 1927)
Commonwealth v. Ill. Cent. R. R.
129 S.W. 96 (Court of Appeals of Kentucky, 1910)

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Bluebook (online)
54 Va. Cir. 392, 2001 Va. Cir. LEXIS 191, Counsel Stack Legal Research, https://law.counselstack.com/opinion/erichsen-v-city-of-norfolk-vaccnorfolk-2001.