Mt. Lookout Community Council v. Cincinnati

2023 Ohio 1729, 215 N.E.3d 599
CourtOhio Court of Appeals
DecidedMay 24, 2023
DocketC-220533
StatusPublished

This text of 2023 Ohio 1729 (Mt. Lookout Community Council v. Cincinnati) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mt. Lookout Community Council v. Cincinnati, 2023 Ohio 1729, 215 N.E.3d 599 (Ohio Ct. App. 2023).

Opinion

[Cite as Mt. Lookout Community Council v. Cincinnati, 2023-Ohio-1729.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

MT. LOOKOUT COMMUNITY : APPEAL NO. C-220533 COUNCIL, TRIAL NO. A-2103378 : Plaintiff-Appellant, : O P I N I O N. vs. : CITY OF CINCINNATI, : and : CITY OF CINCINNATI ZONING BOARD OF APPEALS, :

Defendants-Appellees, :

and : L&D REAL ESTATE HOLDINGS, LLC, : L&D REAL ESTATE PROPERTIES, LLC, :

and :

R2 PARTNERSHIP, :

Intervenors-Defendants-Appellees. :

Civil Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Reversed and Cause Remanded

Date of Judgment Entry on Appeal: May 24, 2023 OHIO FIRST DISTRICT COURT OF APPEALS

Suder LLC and Sean S. Suder for Plaintiff-Appellant,

Emily Smart Woerner, City Solicitor, and Kevin M. Tidd, Senior Assistant City Solicitor, for Defendants-Appellees,

Wood & Lamping LLP and Kathleen F. Ryan, for Intervenors-Defendants-Appellees.

2 OHIO FIRST DISTRICT COURT OF APPEALS

CROUSE, Presiding Judge.

{¶1} In this administrative appeal, we consider whether the Zoning Hearing

Examiner (“ZHE”) is permitted under the Cincinnati Zoning Code to grant a use

variance to permit demolition of existing buildings in a zoning overlay district where

demolition is not generally permitted. For the following reasons, we determine that

demolition is not a “use” for the purposes of a use variance.

I. Factual and Procedural History

{¶2} Plaintiff-appellant Mt. Lookout Community Council (“MLCC”) brought

an administrative appeal before the court of common pleas to challenge the decision

of defendant-appellee Zoning Board of Appeals (“ZBA”). The ZBA, on behalf of

defendant-appellee city of Cincinnati (collectively, the “city appellees”), affirmed the

ZHE’s decision to grant a use variance to intervenors-defendants-appellees R2

Partnership, L&D Real Estate Holdings, LLC, and L&D Real Estate Properties, LLC,

(collectively, the “Developers”). The use variance purports to allow the Developers to

demolish four buildings in Cincinnati’s Mt. Lookout neighborhood, located at 1009,

1011, 1013, and 1015 Delta Avenue (the “property”).

{¶3} In February 2020, the Developers filed an application with the city to

demolish the existing single-family homes located on their property and replace them

with a multi-family development. Under the Cincinnati Zoning Code, the property is

located in a Commercial Neighborhood-Pedestrian (“CN-P”) zone. The property is also

within the Mt. Lookout Square Urban Design Overlay District (“UDOD”), and partially

within a Hillside Overlay District. The zoning code generally permits single-family and

multi-family dwellings within the CN-P zone. Cincinnati Municipal Code Schedule

1409-07. However, at the time the Developers filed their application, the zoning code

3 OHIO FIRST DISTRICT COURT OF APPEALS

prohibited demolition within the UDOD unless the demolition had been ordered by

the Director of Buildings and Inspections for reasons of public health and safety, and

at least one of several other conditions had been met. Former Cincinnati Municipal

Code 1437-09(i), effective June 16, 2018.

{¶4} The ZHE denied the Developers’ 2020 application based on the

restriction against demolition in the UDOD. The Developers appealed to the ZBA,

which affirmed the denial. In the ZBA’s decision, it noted in dicta that “a use variance

as described in Cincinnati Municipal Code § 1445-16 may be considered when the ZHE

determines that the standards of the Urban Design Overlay District cannot be met.”

{¶5} On February 19, 2021, the Developers filed their second application for

zoning relief. In their second application, the Developers requested a use variance to

allow demolition of the buildings on the property, as suggested by the ZBA. The ZHE

approved the use variance. MLCC appealed the ZHE’s decision to the ZBA, which

affirmed the grant of the use variance.

{¶6} MLCC subsequently filed an administrative appeal of the ZBA’s decision

in the court of common pleas. Following a hearing, the court affirmed the ZBA’s

decision. This appeal timely followed.

II. Analysis

{¶7} In its sole assignment of error, MLCC argues that the trial court erred in

holding that a use variance can be used to permit demolition of the subject properties.

MLCC centers its argument on three main issues: (1) that Ohio law permits a use

variance only to permit a specifically prohibited land use, and only when the

legislature has specifically delegated such authority; (2) that demolition does not

constitute a land use; and (3) that the city council has not, through the Cincinnati

4 OHIO FIRST DISTRICT COURT OF APPEALS

Zoning Code, delegated the authority to the ZHE to grant use variances from the

regulations pertaining to the UDOD.

{¶8} In an administrative appeal under R.C. Chapter 2506, the court of

appeals “reviews only questions of law.” Citizens Against Blasting On Our Miami

(CABOOM) v. Anderson Twp. Bd. of Zoning Appeals, 1st Dist. Hamilton Nos.

C-120011, C-120012, C-120013, C-120014 and C-120015, 2012-Ohio-6145, ¶ 11, citing

R.C. 2506.04. For this reason, the appropriate standard of review is de novo. Crutcher

v. Oncology/Hematology Care, Inc., 2022-Ohio-4105, 201 N.E.3d 446, ¶ 55 (1st

Dist.), citing Goodyear Tire & Rubber Co. v. Aetna Cas. & Sur. Co., 95 Ohio St.3d 512,

2002-Ohio-2842, 769 N.E.2d 835, ¶ 4. As such, the court gives no deference to the

interpretations of law made by the administrative bodies below. In re Application of

Black Fork Wind Energy, L.L.C., 156 Ohio St.3d 181, 2018-Ohio-5206, 124 N.E.3d

787, ¶ 43 (Kennedy, J., concurring) (“And because the interpretation of a statute is a

question of law, we review the board’s interpretation de novo and without deference.”).

{¶9} MLCC argues that the ZHE does not have the authority to allow

demolition in the UDOD by way of a use variance. Specifically, MLCC argues that

“demolition” is not a “use” in the context of the zoning code.

{¶10} Under R.C. 713.11, the legislative authority of a municipality may

delegate the power to grant use and area zoning code variances to an administrative

body. Schomaeker v. First Natl. Bank, 66 Ohio St.2d 304, 306, 421 N.E.2d 530 (1981).

A use variance permits land uses for purposes other than those

permitted in the district as prescribed in the relevant regulation. An

example of a use variance is a commercial use in a residential district.

Area variances do not involve uses, but rather structural or lot

5 OHIO FIRST DISTRICT COURT OF APPEALS

restrictions. An example of an area variance is relaxation of setback

lines or height restrictions.

Id. at 306-307. R.C. 713.11 makes clear that the administrative body’s power to permit

exceptions and variations to the general zoning regulations derives from, and is

limited by, the grant of such authority from the municipality. See id. at 307 (“Given

the broad grant of power in R. C. 713.11 to allow use and area variances, a municipal

corporation is not required to delegate to its planning commission the full power

authorized by statute.”).

{¶11} At issue in this case is a use variance. The Cincinnati Municipal Code

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Related

Schomaeker v. First National Bank of Ottawa
421 N.E.2d 530 (Ohio Supreme Court, 1981)
Biglin v. S (In re Black Fork Wind Energy, L. L.C.)
124 N.E.3d 787 (Ohio Supreme Court, 2018)
Crutcher v. Oncology/Hematology Care, Inc.
2022 Ohio 4105 (Ohio Court of Appeals, 2022)
Goodyear Tire & Rubber Co. v. Aetna Cas. & Sur. Co.
2002 Ohio 2842 (Ohio Supreme Court, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 1729, 215 N.E.3d 599, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mt-lookout-community-council-v-cincinnati-ohioctapp-2023.