Mac Sawyers v. Louisville Jefferson County Metro Government Offices of Planning & Design Services, Develop Louisville

CourtCourt of Appeals of Kentucky
DecidedFebruary 8, 2024
Docket2022 CA 001225
StatusUnknown

This text of Mac Sawyers v. Louisville Jefferson County Metro Government Offices of Planning & Design Services, Develop Louisville (Mac Sawyers v. Louisville Jefferson County Metro Government Offices of Planning & Design Services, Develop Louisville) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mac Sawyers v. Louisville Jefferson County Metro Government Offices of Planning & Design Services, Develop Louisville, (Ky. Ct. App. 2024).

Opinion

RENDERED: FEBRUARY 9, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-1225-MR

MAC SAWYERS APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE MITCHELL PERRY, JUDGE ACTION NO. 19-CI-007889

LOUISVILLE JEFFERSON COUNTY METRO GOVERNMENT OFFICES OF PLANNING & DESIGN SERVICES; DEVELOP LOUISVILLE; AND LOUISVILLE JEFFERSON COUNTY METRO GOVERNMENT BOARD OF ZONING ADJUSTMENTS APPELLEES

OPINION REVERSING AND REMANDING

** ** ** ** **

BEFORE: EASTON, JONES, AND LAMBERT, JUDGES.

LAMBERT, JUDGE: Mac Sawyer1 has appealed from the opinion and order of

the Jefferson Circuit Court upholding a decision of the Louisville Metro Board of

1 The appellant’s last name is listed as Sawyer or Sawyers throughout the record, including the notice of appeal, where it is listed as Sawyer in the caption and Sawyers in the body. We shall refer to him as Sawyer in this Opinion as that is the version used in his appellate brief. Zoning Adjustment (the Board) affirming the denial of Sawyer’s application to

declare his nonresidential use of property on National Turnpike as a legal,

nonconforming use due to a lack of continuous use since 1943. Because we hold

that the Board’s decision was arbitrary and that the circuit court erred in affirming,

we reverse and remand.

In May 2019, Sawyer filed a Nonconforming Rights Application with

the Louisville Metro Planning & Design Services regarding the use of his property

at 9705 National Turnpike in Louisville, Kentucky, which was zoned residential.

He described his nonconforming use as follows:

The use is commercial/industrial property used to store house and building moving equipment, including, but not limited to, backhoes, trucks, trailers, cribbing, timber, pipes and other related equipment stored over the entire lot, storage of general contracting equipment, including, but not limited to, construction supplies, heavy equipment, tools, machines, etc., storage and dispatch of carpet cleaning vans and carpet cleaning equipment. In the front portion and garage there are jacks, jacking machines, blacksmith supplies, and [a] blacksmith shop.

Included with his application were affidavits, maps, permits, and photos of

equipment storage, job sites, workers, transport, completed jobs, blacksmith work,

and steel and equipment handling “showing that the property has been used as

commercial/industrial property since the 1930s.” He claimed these documents

established that the property never stopped being used commercially.

-2- Sawyer attached his own affidavit, outlining his use and ownership of

the property since the 1970s, including his interactions with the Metro Government

employees, as well as the use by prior owners. He also included a chronology of

prior owners back to 1933 and witnesses who remembered that “maybe as early as

1937” a business buying and selling steel had been operated at the property, along

with supporting affidavits.

The record contains e-mail communications from and between city

planners. Associate planner Nia Holt sent an e-mail on May 24, 2019, as follows:

The applicant is requesting commercial uses (carpet cleaning, blacksmith shop, & house moving businesses [storage yard and contractor shop written onto printed out message]) and the equipment storage associated with the commercial uses in the R-4 zoning district. The property is located outside of the original city and the applicant was required to provide evidence going back to 1943. PVA list the property as single-family residence. Zoning maps from the 40s list the subject property as zoning class “A – One Family District.” Later zoning maps from the 1960s and 1990s list the property as R-4. The Directories show a listing of the business or the property owner listed in the deeds provided from 2000, 1998, 1993, 1991, 1985, 1975, 1972, 1971, and 1963. The aerial maps from [sic] do not show outdoor storage until the 1980s.

The applicant states in the application that he has lived and work[ed] out of this property for over 40 years (see attached timeline). He rented from the previous owner before he bought the house and all the businesses on the property (see attached affidavit). Affidavits from neighboring property owners state that the property has been used both as a residence and a business since the

-3- late ‘30s/early 40s. The applicant has provided pictures from dating back to the 1960s of the various businesses that have been based on the property and its workers. There are also records (invoices, tax forms, work orders, etc.) of the business going back to the 1970s. I have attached the summary of the documents. I have the entire binder in my office if you would like to see in the information.

And on June 6, 2019, Ms. Holt sent an e-mail to Sawyer:

We have reviewed the materials submitted for this case. We cannot identify a specific use that can be consistently dated back nor conclusive evidence to support nonconforming rights to 1943. The team of senior planners have determined that this case cannot be approved at staff level and you will need to appeal to the Board of Zoning Adjustment (BOZA). The first step is to tell us the exact land use or uses from the Louisville Metro Land Development Code (LDC) you are requesting nonconforming rights for so we can respond to that use(s) request in our letter response. This way you will have already identified the uses you are appealing BOZA for. If you are requesting more than one use in your appeal you must submit a plan that shows where on the property each land use is located. I have attached the appropriate section of the LDC and the appeal application for your convenience.

On August 9, 2019, Chris French, a Planning & Design Supervisor,

sent a letter to Sawyer providing him with notice that he had not established the

nonconforming use rights for a blacksmith and contractor’s shop with a storage

yard for 9705 National Turnpike. Pursuant to Kentucky Revised Statutes (KRS)

100.257, Sawyer appealed to the Board. In his appeal, Sawyer maintained that he

had conclusively proven the requisite commercial and industrial use of his property

-4- since the 1930s. Further, alleging that an employee of the agency, April Robbins,

had previously determined that the property was nonconforming, Sawyer argued

the agency should not be permitted to arbitrarily reach a contrary result.

Prior to the public hearing, a Staff Report was completed, which

included a summary of the case, an analysis of the issues, and a conclusion:

STAFF ANALYSIS/FINDINGS

....

The Appellant provided extensive documentation related to his ownership and use of the property for non- residential activities related to uses that fit the M-2 zoning category under a blacksmith, contractor’s shop, and storage yard. However, affidavits from some neighboring property owners, nearby business owners, and relatives of previous owners is the only information that was provided for the time period prior to the 1960s. Staff looked at the files within the Office of Planning and Design Services and could not find any information regarding the use of the property as a blacksmith, contractor’s shop, or storage yard. Staff looked at an aerial photograph from the [sic] 1946 (Attachment 3) which does not show the storage of equipment, vehicles, or materials on the property as discussed in the affidavits. Without information to corroborate the affidavits staff cannot determine that the use existed on the property since 1943.

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Mac Sawyers v. Louisville Jefferson County Metro Government Offices of Planning & Design Services, Develop Louisville, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mac-sawyers-v-louisville-jefferson-county-metro-government-offices-of-kyctapp-2024.