Pickens County v. Talking Rock Bluffs, LLC

CourtCourt of Appeals of Georgia
DecidedMarch 2, 2023
DocketA22A1253
StatusPublished

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

Bluebook
Pickens County v. Talking Rock Bluffs, LLC, (Ga. Ct. App. 2023).

Opinion

SECOND DIVISION RICKMAN, C. J., MILLER, P. J., and PIPKIN, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

March 2, 2023

In the Court of Appeals of Georgia A22A1253. PICKENS COUNTY v. TALKING ROCK BLUFFS, LLC.

PIPKIN, Judge.

This case concerns the proper method to bring a challenge in the superior court

to a local zoning authority’s decision on a rezoning request when it has been asserted

that the current zoning scheme is unconstitutional as applied to the particular property

at issue. In the present case, Talking Rock Bluffs, LLC (“Talking Rock”) filed two

separate actions in the superior court following the denial of its rezoning request – a

petition for writ of certiorari against the Board of Commissioners and others1 and the

present action against Pickens County seeking a declaration that the zoning decision

was unconstitutional and requesting equitable and injunctive relief. Relying on

Diversified Holdings v. City of Suwanee, 302 Ga. 597 (807 SE2d 876) (2017), the

1 The petition for writ of certiorari has not been made a part of the record on appeal. County filed a motion to dismiss the declaratory judgment action, arguing that Talking

Rock’s only means of challenging the zoning decision was by filing a petition for writ

of certiorari. Following a hearing, the trial court denied the motion to dismiss but

further ordered Talking Rock to elect which of the actions it wished to pursue so as to

avoid the prohibition of simultaneous prosecutions.2 See OCGA § 9-2-5. We granted

the County’s application for interlocutory review, and this appeal timely followed.

As set out in numerous cases, the answer to the question presented by this appeal

turns on whether, in considering the rezoning request, the local zoning authority acted

in a legislative capacity or a quasi-judicial capacity. If the rezoning decision is

classified as legislative, the party seeking review may file a complaint in the superior

court, and that court is authorized to conduct a de novo review and may consider

evidence not presented to the local tribunal. Stendahl v. Cobb County, 284 Ga. 525,

526-527 (1) (668 SE2d 723) (2008). However, if the rezoning decision is classified as

quasi-judicial or adjudicative, the property owner may challenge the denial of its

rezoning application only by way of a petition for writ of certiorari to the superior court,

see OCGA § 5-4-1, and the superior court is bound by the facts and evidence presented

2 The County in fact requested this alternative relief in the form of requiring Talking Rock to elect between the two actions in the event the trial court denied its motion to dismiss.

2 to the local zoning authority. Forsyth County v. Mommies Properties, LLC, 359 Ga.

App. 175, 184 (2) (855 SE2d 126) (2021).

For more than fifty years, our law appeared settled that a zoning authority acts

in a legislative capacity when considering a rezoning request challenging the

constitutionality of a zoning ordinance as applied to a particular piece of property, and,

accordingly, the proper procedure to challenge the zoning authority’s grant or denial of

the rezoning request is to file suit in the superior court, which may then conduct a de

novo review. See Stendahl, 284 Ga. at 526 (1) (“When a zoning authority either grants

or denies an application for re-zoning, it acts in a legislative capacity, and when the

constitutionality of that enactment is challenged in court, it is afforded de novo

review[.]”); Mayor & Aldermen of the City of Savannah v. Rauers, 253 Ga. 675, 675 (1)

(324 SE2d 173) (1985); Toomey v. Norwood Realty Co., 211 Ga. 814, 816-817 (1) (89

SE2d 265) (1955); Presnell v. McCollum, 112 Ga. App. 579, 579 (2) (145 SE2d 770)

(1965) (“The acts of a county commissioner in zoning matters are not a judicial or

quasi-judicial function, but a legislative function, to which the writ of certiorari will not

lie.”).

However, in Diversified, our Supreme Court arguably departed from this

longstanding precedent. See Schroeder Holdings, LLC v. Gwinnett County, 2023 Ga.

3 App. LEXIS 4, *7 (1), 2023 WL 109401 (Case No. A22A1585, decided Jan. 5, 2023)

(“We recognize that there is a strong argument that, after Diversified, rezoning

decisions must be treated as quasi- judicial acts which may be reviewed only by writ of

certiorari.”). In Diversified, as in the present case, the property owner sought rezoning

of its property, which it had been unable to sell as then-classified, claiming, among

other things, that the existing zoning regulation was unconstitutional as applied to the

property. 302 Ga. at 598-599 (I). The zoning authority denied the rezoning request, and

the property owner filed a declaratory judgment action in the superior court, alleging

that the denial of the rezoning request constituted an unconstitutional taking of the

property. Id. at 598 (I). Following a bench trial, the trial court upheld the zoning

authority’s decision, and the property owner filed both a direct appeal and an

application for discretionary review in the Supreme Court of Georgia. Id. at 598-599 (I).

Before turning to the merits of the appeal, the Supreme Court addressed the threshold

“question of jurisdiction and appellate procedure,” asking “whether a party seeking to

appeal a superior court ruling on an inverse condemnation action is required to file a

discretionary application if that claim is based on a local board’s zoning decision.”

(Emphasis supplied.) Id. at 600 (II). The Court answered the question in the affirmative,

concluding that a ruling on a rezoning application is adjudicative in nature; pertinently

4 here, in doing so, the Court also characterized the local authority’s decision as

“adjudicative in nature.” Id. at 604 (II).

While Pickens County would have us end our analysis there, the question of

Diversified’s reach is not so simple or straightforward. First, the Supreme Court did not

mention or overrule its prior precedent, which seemingly held to the contrary. Further,

the exact issue in Diversified concerned the proper procedure to follow when appealing

from a superior court’s decision reviewing a local zoning authority’s decision, whereas

the present case concerns the proper procedure to follow when seeking review of the

local zoning authority’s decision in the superior court. And, despite the language in

Diversified seemingly classifying the local zoning authority’s acts as quasi-judicial, the

Supreme Court did not pause over the fact that the property owner in Diversified filed

a complaint in the superior court, not a petition for writ of certiorari, or over the fact

that the trial court conducted a bench trial and made extensive findings of fact.

Diversified, 302 Ga. at 598-699 (I).3

3 It is worth noting that two Georgia Supreme Court Justices have since questioned the extent of Diversified’s reach. In IDI Logistics v. City of Douglasville, 312 Ga.

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Related

Mayor & Aldermen of City of Savannah v. Rauers
324 S.E.2d 173 (Supreme Court of Georgia, 1985)
Toomey v. Norwood Realty Co., Inc.
89 S.E.2d 265 (Supreme Court of Georgia, 1955)
Presnell v. McCollum
145 S.E.2d 770 (Court of Appeals of Georgia, 1965)
Stendahl v. Cobb County
668 S.E.2d 723 (Supreme Court of Georgia, 2008)
Diversified Holdings, LLP v. City of Suwanee
807 S.E.2d 876 (Supreme Court of Georgia, 2017)
White v. State
823 S.E.2d 794 (Supreme Court of Georgia, 2019)

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Pickens County v. Talking Rock Bluffs, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pickens-county-v-talking-rock-bluffs-llc-gactapp-2023.