Huddleson v. Inhabs. of the Town of Eliot

CourtSuperior Court of Maine
DecidedJuly 6, 2004
DocketYORap-03-35
StatusUnpublished

This text of Huddleson v. Inhabs. of the Town of Eliot (Huddleson v. Inhabs. of the Town of Eliot) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Huddleson v. Inhabs. of the Town of Eliot, (Me. Super. Ct. 2004).

Opinion

STATE OF MAINE SUPERIOR COURT

CIVIL ACTION YORK, ss. DOCKET NO. AP-03-35 cap AYPR- en -

MARK HUDDLESON,

Plaintiff

v. ORDER DOna £ Roy -

INHABITANTS OF THE ‘ ae TOWN OF ELIOT, ™

Defendant JUL 12 2004

Before this court is Plaintiff, Mark Huddelson’s appeal from the decision of the —

Town of Eliot Board of Appeals, pursuant to M. R. Civ. P. 80B. FACTS

Plaintiff, Mark Huddleson is the owner of property located at 99 Bolt Hill Road Eliot, Maine. Plaintiff's property is located in the Defendant, Town of Eliot’s Suburban Zoning District. Plaintiff has a home and operates a towing business on this property. Plaintiff has been operating this business on his property since 1992. Plaintiff's business currently has four towing vehicles and requires that some of the disabled vehicles be stored on his property. Occasionally, Plaintiff will have to hold a vehicle on the property, for 90-120 days. As of May 15, 2003, there were a total of 23.vehicles located on the Plaintiff's property, including tow trucks, personal vehicles, and vehicles that had been towed on to the site. (See R. at 22.)

On February 11, 2003, the Defendant’s Code Enforcement Officer (“CEO”) wrote a letter to Plaintiff, indicating that he was in violation of several of the sections of its

Ordinance. Specifically, Defendant’s CEO cited that Plaintiff was in violation of Article IV § 45-156, operating a business without a conditional use permit, Article IV § 45-290, operating a towing business in the Suburban Zoning District, Article IV § 45-290, operating a parking lot in the Suburban Zone, Article IV § 45-290, operating an auto graveyard in the Suburban Zone, and 30-A M.R.S.A. § 3753 § 3, operating an automobile graveyard and recycling business without a permit. On March 4, 2003, Plaintiff appealed this decision to the Board of Appeals. The Board of Appeals held a hearing on May 15, 2003, and ultimately upheld the Defendant CEO’s decision. Accordingly, on June 23, 2003, Plaintiff appealed to the York County Superior Court. ARGUMENT

Plaintiff contends that the Board of Appeals incorrectly determined that a vehicle towing business is not allowed in the Suburban Zoning District. Specifically, Plaintiff alleges that he was not required to obtain a conditional use permit in order to operate his business. In addition, Plaintiff alleges that his towing business is permitted in the Suburban Zoning District, because it is an “emergency operation” or, in any event, it is no more objectionable than other uses permitted in the Suburban Zone. Finally, Plaintiff argues that his business is neither a “parking lot” nor an “automobile graveyard.” Hence, this court should reverse the decision of the Board of Appeals.

Conversely, Defendant argues that the Board of Appeals decision was correct, because Plaintiff's business is not an “emergency operation,” but it is a “parking lot” and an “automobile graveyard.” In addition, Defendant asserts that Plaintiff's argument that his use is similar to an allowed Suburban Zone use is premature and should be decided by the Planning Board, not the Board of Appeals. Consequently, Defendant contends that this court should affirm the decision of the Defendant's Board

of Appeals. DISCUSSION This court, acting in an intermediate appellate capacity, will review the ZBA’s decision “directly for errors of law, abuse of discretion, or findings not supported by

substantial evidence in the record.” Priestly v. Town of Hermon, 2003 ME 9, { 6, 814

A.2d 995, 997. The Superior Court will affirm the ZBA’s decision unless it is unlawful,

arbitrary, capricious, or unreasonable. Senders v. Town of Columbia Falls, 647 A.2d 93,

94 (Me. 1994). The board’s findings will not be disturbed if supported by substantial

evidence contained in the record. Palesky v. Town of Topsham, 614 A.2d 1307, 1309

(Me. 1992). “Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support the conclusion.” Id. With regard to the factual determinations made by the Board of Appeals, the burden is on Plaintiff to prove that based on the evidence the board should have reached a contrary conclusion. Britton v.

Town of York, 673 A.2d 1322, 1325 (Me. 1996).

Moreover, the Law Court has also held that the interpretation of zoning provisions

is a question of law. Mayberry v. Town of Old Orchard Beach, 599 A.2d 1153, 1154 (Me.

1991). In addition, the contested language must be construed reasonably and with

regard to both the ordinance's specific object and its general structure. Ray v. Town of

Camden, 533 A.2d 912, 914 (Me. 1987). Each undefined term is given its common and

generally accepted meaning unless the context of the statute clearly indicates otherwise.

George D. Ballard, Builder, Inc. v. City of Westbrook, 502 A.2d 476, 480 (Me. 1988). The

Board of Appeal's interpretation of its own ordinance must be reasonable, based on facts in the record, and consistent with the Zoning Ordinance as a whole. See Your

Home, Inc. v. City of Portland, 432 A.2d 1250, 1260 (Me. 1981).

First, a vehicle towing business is not defined nor allowed as an authorized use

within the Suburban Zone, pursuant to the table provided in §45-290. Specifically, this section provides that “any use not listed is a prohibited use.” As a result, Plaintiff argues that his towing business is an "emergency operation," which is permitted in all zones including the Suburban Zone. (See Eliot Zoning Ord. § 45-290.) The Eliot Ordinance defines “emergency operations” as “work made necessary to restore property to a safe condition following a public calamity, or work required to protect persons or property from an imminent exposure to danger or potential danger.” (Eliot Zoning Ord. at § 45:8.)

Here, Plaintiff makes use of his property as a towing business. Plaintiff keeps tow trucks on his property, uses them to retrieve damaged and broke-down vehicles, and brings some of the vehicles back to his property where he stores them for various periods of time. Plaintiff argues that because he responds to “emergencies” on the road, his business constitutes “emergency operations.” Defendant, however, argues that if the court were to find Plaintiff’s towing business constituted an “emergency operation,” then it would be allowing a towing business to be operated in all Zoning Districts. (See Eliot Zoning Ord. at § 45:32.) I find this argument persuasive. Hence, based on a totality of the circumstances, I find that Plaintiffs towing business is not an “emergency operation.”

Plaintiff further argues that if this court should find that the towing business is not an “emergency operation,” then it should find that it is similar to and no more objectionable than other uses permitted in the Suburban Zone. Defendant, however, argues that this court is not in a position to make this determination. Specifically, Defendant asserts that § 45:290 contains a general category of “uses similar to uses requiring a planning board permit,” and makes such uses permissible in the Suburban Zoning District upon review by the Planning Board and not the Board of Appeals.

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Related

Your Home, Inc. v. City of Portland
432 A.2d 1250 (Supreme Judicial Court of Maine, 1981)
Ray v. Town of Camden
533 A.2d 912 (Supreme Judicial Court of Maine, 1987)
Senders v. Town of Columbia Falls
647 A.2d 93 (Supreme Judicial Court of Maine, 1994)
George D. Ballard, Builder, Inc. v. City of Westbrook
502 A.2d 476 (Supreme Judicial Court of Maine, 1985)
Priestly v. Town of Hermon
2003 ME 9 (Supreme Judicial Court of Maine, 2003)
Mayberry v. Town of Old Orchard Beach
599 A.2d 1153 (Supreme Judicial Court of Maine, 1991)
Palesky v. Town of Topsham
614 A.2d 1307 (Supreme Judicial Court of Maine, 1992)
Britton v. Town of York
673 A.2d 1322 (Supreme Judicial Court of Maine, 1996)
Oyster Shell, Inc. v. Town of Damariscotta
2002 ME 23 (Supreme Judicial Court of Maine, 2002)

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