Green Development, LLC a/k/a Wind Energy Development, LLC v. Town of Exeter

CourtSupreme Court of Rhode Island
DecidedJuly 28, 2023
Docket20-244
StatusPublished

This text of Green Development, LLC a/k/a Wind Energy Development, LLC v. Town of Exeter (Green Development, LLC a/k/a Wind Energy Development, LLC v. Town of Exeter) is published on Counsel Stack Legal Research, covering Supreme Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Green Development, LLC a/k/a Wind Energy Development, LLC v. Town of Exeter, (R.I. 2023).

Opinion

Supreme Court

No. 2020-244-Appeal. (WC 18-636)

Green Development, LLC a/k/a Wind : Energy Development, LLC

v. :

Town of Exeter et al. :

NOTICE: This opinion is subject to formal revision before publication in the Rhode Island Reporter. Readers are requested to notify the Opinion Analyst, Supreme Court of Rhode Island, 250 Benefit Street, Providence, Rhode Island 02903, at Telephone (401) 222-3258 or Email opinionanalyst@courts.ri.gov, of any typographical or other formal errors in order that corrections may be made before the opinion is published. Supreme Court

Present: Suttell, C.J., Goldberg, Robinson, Lynch Prata, and Long, JJ.

OPINION

Justice Long, for the Court. This matter arises from a decision by the

defendant, the Town of Exeter1 (defendant or the town), to pause, and subsequently

to amend, its zoning ordinance, which prevented the plaintiff, Green Development,

LLC a/k/a Wind Energy Development, LLC (plaintiff), from developing three

commercial solar-field projects (solar-field projects) in Exeter, Rhode Island. The

plaintiff appeals from a judgment of the Superior Court in favor of the defendant in

this action seeking injunctive and declaratory relief, as well as damages and

attorneys’ fees.

1 The plaintiff also brought this action against each member of the Exeter Town Council and the Treasurer of the Town of Exeter in their official capacities. We refer to the town itself exclusively for the sake of clarity and to remain consistent with the Superior Court. -1- The plaintiff challenges the Superior Court’s denial of its request (1) to enjoin

the town’s enforcement of an emergency moratorium ordinance that prevented

review of plaintiff’s solar-field projects; (2) to declare as ultra vires the enactment

of the moratorium ordinance, and that the moratorium ordinance was void ab initio;

(3) to declare that plaintiff’s solar-field projects are vested pursuant to G.L. 1956

§ 45-24-44 of the Rhode Island Zoning Enabling Act (Zoning Enabling Act); (4) to

declare that the moratorium ordinance violates the doctrine of equitable estoppel and

is thus inapplicable to plaintiff’s solar-field projects; and (5) to declare that the

town’s enactment of the moratorium ordinance violates plaintiff’s procedural and

substantive due-process rights.

For the reasons stated herein, we affirm the judgment of the Superior Court.

Facts and Procedural History

In July 2018, the Exeter Town Council adopted a zoning ordinance (the Green

ordinance) that authorized the construction of commercial solar fields as of right in

RU-3 and RU-4 zones in Exeter, so long as they conformed with specific lot and

acreage requirements. The Green ordinance removed many of the then-existing

zoning restrictions on commercial solar fields previously established in a 2015

ordinance. The town council approved the Green ordinance despite concerns from

local officials including the town’s planning board. Specifically, these concerns

stemmed from the number of outstanding applications before the town and the

-2- potential overdevelopment of commercial solar fields in Exeter. Further, this threat

of overdevelopment created a concern that the proposed projects would not comply

with Exeter’s comprehensive plan.

On October 16, 2018, after the town council adopted the Green ordinance,

plaintiff filed three submissions with the town planner for development of three

solar-field projects in RU-3 and RU-4 zones (October submissions).2 The plaintiff

submitted three “Application for Land Development, Subdivision of Land, and/or

Development (Site) Plan Review” forms; under “application type” on each form,

plaintiff selected “pre-application.” Additionally, the letter of transmittal

accompanying each of the October submissions noted that plaintiff was submitting

materials for pre-application plan review of the relevant proposed solar-field project.

The town planner classified plaintiff’s October submissions as pre-applications for

master plan review pursuant to Rhode Island’s land development statutory

framework. The first step in the master plan review process involves an applicant

submitting information for review and discussion with the planning board and may

eventually result in the issuance of letters of completeness by the town planner.

2 Before plaintiff filed its October submissions, the town council adopted a new ordinance on September 4, 2018, that would have likely prohibited plaintiff’s solar- field projects. The town council rescinded the September 2018 ordinance during its October 2018 meeting, effectively reinstating the Green ordinance. -3- On November 6, 2018, town voters elected new members of the town council;

at some point thereafter, but prior to the November 22, 2018 inauguration, a newly-

elected town council member, Calvin Ellis, discussed with the town planner the

possibility of issuing a moratorium on new solar development projects. Based on

the town planner’s status as a part-time employee and the influx of applications the

town received for solar-field projects, the town planner agreed that a moratorium

would allow the town to meet the rising demand given its finite resources. As a

result of this conversation, Mr. Ellis asked the town planner to draft initial language

for an ordinance accomplishing that purpose. Additionally, although the town’s

planning board typically reviews an applicant’s submissions one month after filing,

due to time constraints at the November 27, 2018 planning board meeting, the

planning board did not review plaintiff’s October submissions and instead planned

to review them at a January 2019 meeting.

On December 10, 2018, the town council enacted a sixty-day moratorium

ordinance applicable “to all proceedings, applications and petitions not vested

pursuant to [G.L. 1956 §] 45-24-44 * * *.” Section five of the moratorium ordinance

contains a vesting clause that defines a vested application as a proposal for solar-

field project “for which an applicant has submitted all the required materials for a

Master Plan meeting * * * and has been certified complete by the Administrative

Officer * * *.” When the town enacted the moratorium ordinance, plaintiff’s

-4- October submissions remained pending and had not been certified as complete. The

plaintiff filed an action challenging the validity of the moratorium ordinance the

following day. 3

On January 7, 2019, the town amended its zoning ordinance to change its

definition and description of vested rights; thereafter, on February 4, 2019, the town

council enacted a final ordinance prohibiting utility-scale solar-field projects in

RU-3 and RU-4 residential zones.

On March 21, 2019, the Superior Court denied plaintiff’s request to enjoin

enforcement of the emergency moratorium and rejected plaintiff’s request for a

declaration invalidating the moratorium. The trial justice ultimately determined,

among other things, that the town permissibly enacted the moratorium ordinance

pursuant to its emergency powers under Article IV, § 411 of the Exeter Town

Charter. In a subsequent decision on cross-motions for summary judgment, issued

on May 13, 2020, the trial justice rejected plaintiff’s claim that its October

submissions fell beyond the scope of the moratorium based on plaintiff’s theory that

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

Related

Such v. State
950 A.2d 1150 (Supreme Court of Rhode Island, 2008)
Waterman v. Caprio
983 A.2d 841 (Supreme Court of Rhode Island, 2009)
Denomme v. Mowry
557 A.2d 1229 (Supreme Court of Rhode Island, 1989)
West v. McDonald
18 A.3d 526 (Supreme Court of Rhode Island, 2011)
Stephen L. Key v. Brown University
163 A.3d 1162 (Supreme Court of Rhode Island, 2017)
Summit Ins. Co. v. Stricklett
199 A.3d 523 (Supreme Court of Rhode Island, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Green Development, LLC a/k/a Wind Energy Development, LLC v. Town of Exeter, Counsel Stack Legal Research, https://law.counselstack.com/opinion/green-development-llc-aka-wind-energy-development-llc-v-town-of-exeter-ri-2023.