H4IT Properties, LLC v. Chelan County

CourtCourt of Appeals of Washington
DecidedOctober 3, 2024
Docket39772-6
StatusUnpublished

This text of H4IT Properties, LLC v. Chelan County (H4IT Properties, LLC v. Chelan County) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
H4IT Properties, LLC v. Chelan County, (Wash. Ct. App. 2024).

Opinion

FILED OCTOBER 3, 2024 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

H4IT PROPERTIES, LLC, a Washington ) limited liability company, ) No. 39772-6-III ) Appellant, ) ) v. ) ) UNPUBLISHED OPINION CHELAN COUNTY, a Washington ) municipal corporation, ) ) Respondent. )

STAAB, A.C.J. — H4IT Properties, LLC (H4IT) purchased a residence in Chelan

County (County) with the intent to use it as a short-term rental. Although the County had

placed restrictions on permits for short-term rentals, H4IT sought a permit as an existing

nonconforming short-term rental. The County denied the permit and a hearing examiner

denied H4IT’s appeal. H4IT filed a land use petition (LUPA1) challenging the hearing

examiner’s decision.

H4IT raises three arguments on appeal, but we consolidate the first two issues in

our analysis. H4IT contends that the hearing examiner misconstrued the legal effect of a

settlement agreement between the County and the previous owners of the property and

1 Chapter 36.70C RCW. No. 39772-6-III H4IT Props. LLC v. Chelan County

failed to consider evidence that the property had been historically used as a

nonconforming short-term rental. H4IT also contends that the superior court erred in

failing to articulate the basis for its conclusion that Chelan County’s newly adopted

regulations on short-term rentals, and its denial of H4IT’s application for a short-term

rental permit resulted in an unconstitutional taking. We disagree with these claims and

affirm.

BACKGROUND

The following facts are set forth from the hearing examiner’s unchallenged

findings.

On August 25, 2020, the County adopted “a moratorium on the designation,

permitting, constructions, development, expansion, remodeling, creation, locating, and

sitting of short term rental uses.” Ex. C-001-003.2 The moratorium was extended twice,

but ended on the effective date of the Short-Term Rental code, September 27, 2021.

Chelan County Code (CCC) 11.88.290(4)(A)(i). The newly enacted “Short-Term Rental

Code” created a permitting system for both new and already existing short-term rentals and

provided different requirements for each. See CCC 11.88.290. The purpose of this code

was “to “establish regulations for the operation of short-term rentals as defined in [c]hapter

14.98, within the unincorporated portions of Chelan County.” CCC 11.88.290(1)(B).

2 Exhibit C-001-003 references the previous Chelan County Code located at the end of the Respondent’s Brief under Exhibit C.

2 No. 39772-6-III H4IT Props. LLC v. Chelan County

The property in question is described as a ten-bedroom single-family residence

located near Lake Wenatchee in Chelan County. The property is zoned Rural Residential

2.5 (RR 2.5).

Prior to H4IT’s purchase, the property had been used by the prior owners as an

illegal “lodging facility” with no conditional use permit (CUP). Even prior to the change

in zoning laws, the County Code required a lodging facility operating in a zone RR 2.5 to

obtain a CUP. The previous owners were told that they did not qualify for an existing

nonconforming short-term rental permit.

On October 14, 2020, the County filed a notice of order against the previous

owners of the property for using the property as an illegal lodging facility. The prior

owners and the County eventually entered into a settlement agreement pertaining to the

notice of order. Within the settlement agreement, the previous owners admitted that the

property had been used as a lodging facility on one occasion in a manner not authorized

by, and in violation of, the Chelan County Code. The previous owners agreed not to

operate the property as a short-term rental or lodging facility in the future without first

obtaining all permits. They also agreed to notify any future potential purchasers of the

property that the property may not be used as a short-term rental or lodging facility

“without first obtaining any and all required permits ‘which may or may not be granted

by the County.’” Clerk’s Papers (CP) at 14.

3 No. 39772-6-III H4IT Props. LLC v. Chelan County

H4IT purchased the property on December 30, 2021 and filed an application for a

short-term rental permit on December 31, 2021. At the time of H4IT’s purchase, the

moratorium was still in effect, prohibiting the issuance of new short-term rental permits.

Additionally, at the time H4IT purchased the property, it was not being used as a short-

term rental.

H4IT’s permit application was denied. The hearing examiner affirmed this denial.

The hearing examiner concluded that H4IT could not show that the property qualified as

an existing nonconforming short-term rental because the previous owners were not

operating a legally established rental. The hearing examiner found that H4IT’s evidence,

that the previous owners earned money and paid taxes in 2020 by renting the property,

was not proof that the property was previously used as a nonconforming short-term

rental. “Monies earned and taxes paid for an illegal operation does not automatically

qualify a new owner as legally operating.” CP at 14. In addition, the hearing examiner

found that while the settlement agreement resolved the prior code violations, the

agreement was not evidence that H4IT was entitled to receive a short-term rental permit.

H4IT filed a LUPA petition in superior court. The superior court affirmed the

hearing examiner’s decision. Additionally, the court found the land use decision did not

violate the constitutional rights of H4IT. H4IT appealed to this court.

4 No. 39772-6-III H4IT Props. LLC v. Chelan County

On appeal, H4IT challenges the hearing examiner’s determination that, since the

previous owners operated an illegal lodging facility, H4IT did not qualify for existing

nonconforming status. In addition, H4IT contends that the hearing examiner committed

clear error in applying the law to the facts when he concluded:

“To the extent that the Appellant is arguing that the prior, unpermitted and illegal use of the property as a lodging facility justifies the granting of a short term rental permit, the Hearing Examiner rejects this argument as not supported by the Chelan County Code.”

Appellant’s Br. at 14 (quoting hearing examiner’s COL 5; AR 5).

ANALYSIS

1. STANDARD OF REVIEW

“Judicial review of land use decisions is governed by LUPA.” Whatcom County

Fire Dist. No. 21 v. Whatcom County, 171 Wn.2d 421, 426, 256 P.3d 295 (2011). In a

LUPA appeal, this court “sits in the same position as the superior court.” Id. We do not

give deference to the superior court’s decision. Griffin v. Thurston County, 165 Wn.2d

50, 55, 196 P.3d 141 (2008). Instead, we apply the LUPA standards to the administrative

record and hearing examiner’s decision, giving deference to the hearing examiner’s legal

and factual determinations. Durland v. San Juan County, 174 Wn. App. 1, 12, 298 P.3d

757 (2012).

5 No. 39772-6-III H4IT Props. LLC v. Chelan County

To set aside a land use decision, the party seeking relief must establish one of six

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