Reed Farms, LLC v. Sussex County Council

CourtCourt of Chancery of Delaware
DecidedJuly 18, 2025
DocketC.A. 2021-0552-BWD
StatusPublished

This text of Reed Farms, LLC v. Sussex County Council (Reed Farms, LLC v. Sussex County Council) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reed Farms, LLC v. Sussex County Council, (Del. Ct. App. 2025).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

REED FARMS, LLC, a Delaware ) limited liability company, ) ) Petitioner, ) ) v. ) C.A. No. 2021-0552-BWD ) SUSSEX COUNTY COUNCIL, a ) political subdivision of the State of ) Delaware, ) ) Respondent. )

MEMORANDUM OPINION RESOLVING CROSS-MOTIONS FOR SUMMARY JUDGMENT

Date Submitted: June 11, 2025 Date Decided: July 18, 2025

David C. Hutt, Michelle Bounds, MORRIS JAMES LLP, Georgetown, DE; Attorneys for Petitioner Reed Farms, LLC.

David N. Rutt, MOORE & RUTT, P.A., Georgetown, DE; Attorneys for Respondent Sussex County Council.

DAVID, V.C. The petitioner in this action, Reed Farms, LLC, seeks a determination that

Sussex County Council acted in an arbitrary and capricious manner when it rejected

an application to amend the County’s future land use map to change the designation

of a parcel of land northwest of Milton from a “low density area” to a “developing

area.” In denying the application, County Council explained why the subject

property should not be designated as a “industrial area” but did not address why the

requested “developing area” designation was inappropriate. Because County

Council answered the wrong question when it denied the application, its decision

was arbitrary and capricious and cannot stand. Judgment is entered for the petitioner.

The petitioner’s application must be resubmitted to County Council for a new public

hearing and a new vote.

I. BACKGROUND

A. The Parties, The Property, And The Plan

Reed Farms, LLC (“Petitioner”), a Delaware limited liability company, owns

67.31 acres of real property located on the south side of Delaware Route 16 and west

of Delaware Route 30, northwest of the town of Milton (the “Property”).1 See

Appendix, Ex. D.

1 The Property is located at 14888 Gravel Hill Road, Milton, Delaware 19968, and identified as Tax Map Parcels 235-13.00-29.00 and 29.01, and 235-14.00-570.00. App. to Pet’r Reed Farms, LLC’s Opening Br. in Supp. of its Mot. for Summ. J. [hereinafter Appendix], Ex. A at 1, Dkt. 17. 1 Sussex County Council (“County Council”) is the governing body of Sussex

County, a political subdivision of the State of Delaware responsible for reviewing

and deciding whether to approve applications to rezone properties that are within

Sussex County but outside the jurisdiction of other zoning authorities.

In 2018, County Council adopted the Sussex County Comprehensive Plan (the

“Plan”), a 280-page document that “serves as the standard for how development

occurs and how land use is governed in a community over a long-term period.”

SUSSEX CTY. COMPREHENSIVE PLAN (2018) [hereinafter Plan]; Comprehensive Plan,

SUSSEX CTY. DEL., https://sussexcountyde.gov/comprehensive-plan (last visited

July 18, 2025). While “County Code regulates the use of land and creation of lots

and associated improvements,” the Plan “acts as a policy guide for future

development and decision-making.” Plan § 1.5. The Plan attaches a Comprehensive

Zoning Map of Sussex County (“Zoning Map”) “that divides the unincorporated

areas of the County into different zoning districts.” Id. § 1.5.1. Each zoning district

“permits a set of activities and establishes a maximum density of development.” Id.

The Plan contemplates a Future Land Use Plan (the “Land Use Plan”) that

“designates which parts of the County are to be considered growth areas” and guides

the County’s zoning regulations. Id. § 4.4. The Plan also contemplates a Future

Land Use Map (“Land Use Map”) “to help direct the location and type of new

development.” Id. § 4.5. The Land Use Map identifies land use classifications in

2 eleven “areas” throughout Sussex County, including “Rural Areas” and “Growth

Areas” listed from lowest to highest density. Id. § 4.5–1. Rural Areas are

designated:

 Low Density Areas  Protected Lands  Agricultural Preservation Districts  Agricultural Preservation Easements

Id. Growth Areas are divided into:

 Municipalities  Town Centers  Developing Areas  Existing Development Areas  Coastal Areas  Commercial Areas  Industrial Areas

Id.

Because the Plan “is a guide for the future use of land, the . . . [Z]oning [M]ap

must be consistent with the uses and intensities of uses provided for in the [Land

Use Plan]” and “future rezonings should . . . generally be consistent with the [Land

Use Plan].” Id. § 4.5. When the County reviews a land use proposal, it is “reviewed

on its own merit to determine if the proposal is consistent with the [Land Use Map]

and does not have a negative impact on the surrounding area or the County in

general.” Id. Pertinent to the dispute here, in Low Density Areas,

[t]he primary uses envisioned . . . are agricultural activities and homes. Business development should be largely confined to businesses

3 addressing the needs of these two uses. Industrial and agribusiness uses that support or depend on agriculture should be permitted. The focus of retail and office uses in Low Density Areas should be providing convenience goods and services to nearby residents. Commercial uses in these residential areas should be limited in their location, size and hours of operation. More intense commercial uses should be avoided in these areas. Institutional and commercial uses may be appropriate depending on surrounding uses.

Id. § 4.4.3. The zoning districts permitted within Low Density Areas include:

 Agricultural Residential District (AR-1)  Business Community District (B-2)  Medium Commercial District (C-2)  Marine District (M)  Institutional District (I-1)

Id. § 4.5–2. In Developing Areas,

[a] range of housing types are appropriate . . . , including single family homes, townhouses, and multi-family units. In selected areas and at appropriate intersections, commercial uses should be allowed. A variety of office uses would be appropriate in many areas. Portions of the Developing Areas with good road access and few nearby homes should allow for business and industrial parks. Appropriate mixed-use development should also be allowed. In doing so, careful mixtures of homes with light commercial and institutional uses can be appropriate to provide for convenient services and to allow people to work close to home.

Id. § 4.4.2.1. The zoning districts permitted within Developing Areas include:

 Agricultural Residential District (AR-1)  Medium Density Residential District (MR)  General Residential District (GR)  High Density Residential District (HR-1 & HR-2)  Business Community District (B-2)  Business Research (B-3)  Medium Commercial District (C-2)

4  Heavy Commercial District (C-3)  Planned Commercial District (C-4)  Service/Limited Manufacturing District (C-5)  Institutional District (I-1)  Marine District (M)  Limited Industrial District (LI-1)  Light Industrial District (LI-2)  Heavy Industrial District (HI-1)

Id. § 4.5–2. And in Industrial Areas,

lands [are] devoted to concentrations of larger industrial uses including heavier industry, light industry, warehousing, and flex space. Appropriate development in these areas could take the form of conventional industrial parks or planned business parks with a unified design that incorporate a combination of light industry and other business uses. Large, more intensive stand-alone industrial uses should also be directed to these areas.

Id. § 4.4.2.1. The zoning districts permitted within Industrial Areas include:

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Bluebook (online)
Reed Farms, LLC v. Sussex County Council, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reed-farms-llc-v-sussex-county-council-delch-2025.