Fenton v. W. Haven Zon. Bd. of Appeals, No. Cv 93-0349797 (Mar. 3, 1994)

1994 Conn. Super. Ct. 2161
CourtConnecticut Superior Court
DecidedMarch 3, 1994
DocketNo. CV 93-0349797
StatusUnpublished

This text of 1994 Conn. Super. Ct. 2161 (Fenton v. W. Haven Zon. Bd. of Appeals, No. Cv 93-0349797 (Mar. 3, 1994)) is published on Counsel Stack Legal Research, covering Connecticut Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fenton v. W. Haven Zon. Bd. of Appeals, No. Cv 93-0349797 (Mar. 3, 1994), 1994 Conn. Super. Ct. 2161 (Colo. Ct. App. 1994).

Opinion

[EDITOR'S NOTE: This case is unpublished as indicated by the issuing court.] MEMORANDUM OF DECISION Factual Background

On May 18, 1993, the defendant, Frank R. Frumento, submitted an application to the defendant, West Haven Zoning Board of Appeals, for a special exception regarding a vacant lot located at 26 Circle Street and Circle Street abandoned in the City of West Haven. At the same time he submitted an application for property at 30 Circle Street, the subject matter in Docket No. CV 93-0349799 and an application for property located at 40 Circle Street, the subject matter in Docket NO. CV 93-0349798. The only difference between the three applications which might affect the outcome of the appeal in each case was that the property at 26 Circle Street and 30 Circle Street each would have 12-1/2 feet of frontage; the property at 40 Circle Street would have 52.81 feet of frontage. In all other respects the legal issues presented are identical and the plaintiffs and defendants are identical.

In the absence of the special exception these properties located in an R-2 zone require 60 feet of frontage and 8,000 square feet for each lot. Although the square footage of the three lots varies, it is undisputed that in each case the square footage is clearly in excess of the required 8,000 square feet.

Ordinarily the lots in question would be unbuildable because of the absence of the required frontage and if the lots were to be used, a variance would be required. However, Section 10-4.4 of the West Haven Regulations allows special exceptions in residential districts under certain circumstances. These exceptions may be granted by the zoning board of appeals. The regulations provides in pertinent part:

"A. VACANT LOTS CT Page 2162

The Zoning Board of Appeals may grant a Special Exception to the bulk requirements for any lot which does not meet all of the requirements of Section 2-3.2 only as permitted herein below. The Board shall hold a public hearing on the application for such Special Exception and may, in its discretion, grant a special exception only after making the following findings and upon setting the following conditions: . . ."

There then follows seven conditions set forth in seven numbered paragraphs. The first condition requires a general configuration similar to at least 75% of the lots in the area. The third condition requires that the proposal meet all bulk and area requirements other than frontage and square footage requirements. The fourth condition allows the Zoning Board of Appeals to impose certain additional restrictions. The fifth condition prohibits the use of this special exception if a variance is involved. And, the seventh condition allows certain yard requirements to be varied by no more than 10%.

The conditions which are of most importance in the case before the court are the second and sixth conditions. The regulation provides in paragraph 2 as follows:

"The non-compliance relates to Minimum Lot Area or Minimum Street Frontage and further provided that the lot has at least 80% of the required Area and/or Frontage;"

Paragraph 6 provides:

"There has been no prior merger of the lot with an adjoining lot."

Merger is defined in the West Haven Regulations on page 10 as follows:

"MERGER: A lot shall be construed to have been `merged' with an adjoining lot under the `doctrine of merger' whenever two or more parcels of land are consolidated through a combined use, by common owner(s). One or more lots shall have been merged by the establishment CT Page 2163 of any accessory use on a parcel of land contiguous with the parcel on which the principal building is located."

On June 16, 1993, the Board held a public hearing to consider the application for the special exceptions submitted by Frank Frumento. Following the public hearing the board granted each of the three requested special exceptions.

Aggrievement

Aggrievement was essentially uncontested at the hearing and the evidence presented was sufficient to establish that the plaintiffs are aggrieved.

Issues

The plaintiffs raise four main issues.

I. The property does not meet the 80% minimum street frontage requirement necessary to obtain a special exception under Sec. 10-4.4A2.

II. The property is not of the same size and configuration as 75% of the lots on both sides of the street in the block in which the lot is located, as required by the regulation.

III. The property is part of a nonconforming use and merged with the adjacent properties thereby precluding a special exception.

IV. The regulations are invalid if they allow for a special exception for property with more than a minor deviation from the applicable bulk and area requirements.

Holding of the Court

The court finds from a complete review of the record that the West Haven Zoning Board of Appeals could have reasonably found that the lots in question were of the same size and configuration as 75% of the lots on both sides of the street in the block.

The court also finds that the lots in question had not merged. The court observes that merger is often used in relation to arguments concerning nonconforming lots. Principles of nonconformity are unrelated to the matter before this court at this CT Page 2164 time. There is no claim that any of the lots are nonconforming but rather a claim that the lots are entitled to a specific special exception authorized by Sec. 10-4.4A. While it may be permissible for town zoning regulations to involuntarily merge adjoining lots when they are in common ownership, at least in relation to their viability as nonconforming lots, West Haven in its clear definition of merger on page 10 of the regulations, ties merger to consolidation through intentional combined use by common owners. All of the lots in question in the instant case are vacant and the West Haven Zoning Board of Appeals had sufficient evidence before it to conclude that there was no combination by reason of use. Therefore, the Zoning Board of Appeals could reasonably conclude that no merger occurred.

The plaintiffs' most fundamental argument is that the claimed special exception is really a variance without the requirement of hardship. A special exception under Connecticut law allows a property owner to use his property in a manner expressly permitted by the local zoning regulations. A. P. W. Holding Company v. Planning and Zoning Board, 167 Conn. 182, 185 (1974). A variance allows a property owner to use his property in a manner not authorized by the zoning regulations when "owing to conditions especially affecting such property but not affecting generally the district in which it is situated, a literal enforcement of such bylaws, ordinances or regulations would result in exceptional difficulty or unusual hardship so that substantial justice will be done and the public safety and welfare secured . . . ." Conn. General Statutes 8-6. In essence, the plaintiffs argue that Sec. 10-4.1 of the West Haven Regulations turns a variance into a special exception and in doing so eliminates the requirement of a showing of hardship. The court does not agree with the plaintiffs' claim in this respect. Section 10-4.4 pertaining to vacant lots specifically authorizes the Zoning Board of Appeals to grant special exceptions and sets forth the requirements for the granting of those exceptions.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Maykut v. Plasko
365 A.2d 1114 (Supreme Court of Connecticut, 1976)
Bania v. Town of New Hartford
83 A.2d 165 (Supreme Court of Connecticut, 1951)
A.P. & W. Holding Corp. v. Planning & Zoning Board
355 A.2d 91 (Supreme Court of Connecticut, 1974)

Cite This Page — Counsel Stack

Bluebook (online)
1994 Conn. Super. Ct. 2161, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fenton-v-w-haven-zon-bd-of-appeals-no-cv-93-0349797-mar-3-1994-connsuperct-1994.