Fairfax County Board of Supervisors v. Zoning Appeals Board

69 Va. Cir. 129
CourtFairfax County Circuit Court
DecidedOctober 4, 2005
DocketCase No. (Law) 2005-362
StatusPublished

This text of 69 Va. Cir. 129 (Fairfax County Board of Supervisors v. Zoning Appeals Board) is published on Counsel Stack Legal Research, covering Fairfax County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fairfax County Board of Supervisors v. Zoning Appeals Board, 69 Va. Cir. 129 (Va. Super. Ct. 2005).

Opinion

By Judge Arthur B. Vieregg

This case originally came before me on Petitioner Board of Supervisors ’ Writ of Certiorari to review a decision by the Board of Zoning Appeals (the “BZA”) in Appeal Application Number A-2004-MV-012 (the “Demetriou Appeal”). I heard arguments in this case on June 17,2005, and September 23, 2005. My decision follows.

Background

The subject property of this appeal is a single family dwelling located at 8618 Richmond Highway in Alexandria (the “Demetriou property”). It has been owned by Defendant Androula Demetriou and her husband for the past seventeen years. The Demetriou property was built in 1938. Currently, it contains two separate dwelling units. There is insufficient evidence to determine when the property became a two unit property. The Demetriou property is zoned R-2. Residential district, two units per acre. (see R. at 58.) Both parties concede that, given the Demetriou property’s size, unless the property constitutes a nonconforming use, it may only be used as one single family residence.

[130]*130On April 9,2004, Ms. Demetriou received aNotice of Zoning Violation issued by Senior Zoning Inspector Michael L. Simms stating her property violated Fairfax County Zoning Ordinance § 2-501 because it contained two dwelling units. Demetriou appealed the Zoning Inspector’s decision. After hearings on October 5 and December 21,2004, the BZA unanimously voted to reverse the Zoning Inspector’s decision.

On February 28, 2005, the Board of Supervisors filed the instant case, petitioning this Court for a Writ of Certiorari to review the decision of the BZA pursuant to Va. Code § 15.2-2314. This Court granted certiorari. On June 17, 2005, the case was reargued. After consideration of the arguments presented, I found that the BZA had not set forth findings of fact and conclusions of law supporting its reversal of the Zoning Inspector. Pursuant to Va. Code § 15.2-2314, this case was remanded back to the BZA to provide such findings of fact and conclusions of law (hereinafter the “Findings”) with respect to its decision.

On July 26, 2005, the BZA met to issue its Findings. The BZA principally identified two material issues in its Findings: (1) whether use of a second apartment on the Demetriou property constituted a nonconforming use; and (2) whether the application of Va. Code § 15.2-2311(C) (hereinafter the “sixty-day rule”) barred the Zoning Inspector’s zoning violation citation. Va. Code § 15.2-2311(C) provides:

In no event shall a written order, requirement, decision, or determination made by the zoning administrator or other administrative officer be subject to change, modification, or reversal by any zoning administrator or other administrative officer after 60 days have elapsed from the date of the written order, requirement, decision, or determination where the person aggrieved has materially changed his position in good faith reliance on the action of the zoning administrator or other administrative officer unless it is proven that such written order, requirement, decision, or determination was obtained through malfeasance of the zoning administrator or other administrative officer or through fraud. The 60-day limitation period shall not apply in any case where, with the concurrence of the attorney for the governing body, modification is required to correct clerical or other nondiscretionary errors.

The BZA observed that, in order for the second dwelling unit in the Demetriou property to be considered a lawful, nonconforming use, the second unit must have constituted “a lawful use existing on the effective date of the [131]*131zoning restriction.” Patton v. City of Galax, 269 Va. 219, 225, 609 S.E.2d 41 (2005) (internal quotations and citations omitted). The BZA emphasized that, with respect to the appeal of a zoning violation, the landowner bears the burden of showing that the property’s use constituted a nonconforming use. See Knowlton v. Browning-Ferris Industries, 220 Va. 571, 574, 260 S.E.2d 232 (1979). The BZA further explained that incomplete and absent records do not create an exception to this rule. See Front Royal v. Martin Media, 261 Va. 287, 294, 542 S.E.2d 373 (2001).

During the original BZA hearings, the County presented the zoning ordinances dating back to 1941. In 1941, the property was not zoned for two dwelling units. However, between 1946 and 1959, applicable zoning ordinances did permit two dwelling units by issuance of a special use permit. In 1959, the Demetriou property was re-zoned for use only as a single family residence. Thus, the BZA determined that, if the second unit on the Demetriou property constituted a nonconforming use, such a use must have commenced before 1941 or between 1946 and 1959. See Patton, 269 Va. at 225.

The BZA observed that, given the age of the house, many facts and records relating to the Demetriou property were unknown. It further observed that the record did demonstrate two facts with certainty: (1) that the house was built in 1938, and (2) the house container! two apartments as early as 1963. The apartments were noted by an inspector in tax records dating back to 1963. The record reflects that the County’s historic preservation planner had opined that the house’s dormer appeared to have been constructed in the 1950s or 1960s. The County historic preservation planner opined that use of the second dwelling unit commenced after and as a consequence of the construction of this dormer. (See R. at 149.) The County had also presented evidence that no permit granting specific permission for construction of a second unit on the property had been issued. Ultimately, the BZA concluded that Mrs. Demetriou produced insufficient evidence to meet her burden to show that the second dwelling unit constituted a [lawful] nonconforming use.

Despite this finding, the BZA cited the sixty-day rule in reversing the decision ofthe Zoning Inspector. The BZA noted that, in 1984, a partly illegible building -permit for interior alterations had been issued by a zoning administrator. The BZA emphasized that pursuant to Zoning Ordinance § 18-102, as then in effect, the zoning administrator was required to confirm that the property complied with all ordinances before issuing any building permit. Thus, in order to grant a permit, the zoning administrator necessarily had had to ascertain that the building was not in violation of any zoning ordinance. Zoning Ordinance § 18-603 (emphasis added). The BZA therefore concluded that a zoning administrator’s issuance of the 1984 building permit occurred more than [132]*132twenty years earlier and that the permit constituted a “written order, requirement, decision, or determination made by the zoning administrator.” See Va. Code § 15.2-2311 (C). The BZA then concluded that, since the Board of Supervisors failed to present any evidence that the issuance of the building permit was affected by a clerical error, malfeasance or fraud, the issuance of the building permit, including the approval of the use of the Demetriou property, could not have been challenged more than sixty days following its issuance. See id. Based on this reasoning, the BZA voted to reverse the Zoning Inspector’s violation decision.

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Related

Patton v. City of Galax
609 S.E.2d 41 (Supreme Court of Virginia, 2005)
Town of Front Royal v. Martin Media
542 S.E.2d 373 (Supreme Court of Virginia, 2001)
Higgs v. Kirkbride
522 S.E.2d 861 (Supreme Court of Virginia, 1999)
Foster v. Geller
449 S.E.2d 802 (Supreme Court of Virginia, 1994)
Knowlton v. Browning-Ferris Industries of Virginia, Inc.
260 S.E.2d 232 (Supreme Court of Virginia, 1979)
Toone v. Zoning Appeals Board
54 Va. Cir. 33 (Fairfax County Circuit Court, 2000)

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Bluebook (online)
69 Va. Cir. 129, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fairfax-county-board-of-supervisors-v-zoning-appeals-board-vaccfairfax-2005.