Spectrum Healthcare Resources, Inc. v. Prince William County Board of Supervisors

83 Va. Cir. 418, 2011 Va. Cir. LEXIS 134
CourtKing William County Circuit Court
DecidedOctober 5, 2011
DocketCase No. CL 10006525-00
StatusPublished

This text of 83 Va. Cir. 418 (Spectrum Healthcare Resources, Inc. v. Prince William County Board of Supervisors) is published on Counsel Stack Legal Research, covering King William County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Spectrum Healthcare Resources, Inc. v. Prince William County Board of Supervisors, 83 Va. Cir. 418, 2011 Va. Cir. LEXIS 134 (Va. Super. Ct. 2011).

Opinion

By Judge Craig D. Johnston

This case came before me on argument upon the Plea in Bar and Demurrer of CR Associates, Inc. (“CRA”) to the Verified Amended Complaint of Spectrum Healthcare Resources, Inc. (“Spectrum”) and the Plea in Bar and Demurrer of CRA to the Verified Amended Complaint of 3700 Fettler Park, L.L.C. (“Fettler”), as well as the memoranda and motions filed by counsel relating thereto. I.took these under advisement and have decided as follows.

Summary of Decision

For the reasons set forth in more detail below, I will sustain the Pleas in Bar and the Demurrers and will dismiss the Complaints to the extent they seek Writs of Prohibition and to the extent they seek a determination in advance of decision by the Board of Zoning Appeals (“BZA”) and the Board of Supervisors of the appeals now pending before them. I will overrule the Demurrers as to Count I of the Spectrum Complaint and Count III of the Fettler Complaint, each of which seeks to invoke this Court’s independent authority to decide vested rights, but will stay further proceedings as to these Counts pending decisions by the BZA and the Board.

[419]*419 Discussion

The Pleas in Bar seek dismissal of the Complaints for failure to exhaust administrative remedies. Most pleas in bar require an evidentiary hearing, as, generally, there are disputed facts. I have decided, however, that sufficient facts have been established to decide the Pleas in Bar.

The undisputed facts are that there now exist appeals lodged by CRA with the BZA and the Boards with respect to a letter issued by the Zoning Administrator at the request of CRA dated August 23, 2010 (“the First Letter”), and with respect to a letter issued by him at the request of Spectrum and CRA dated December 6, 2010 (“the Second Letter”), and that there are now proceedings before these two Boards to decide these appeals, which have been temporarily stayed by order of the Supreme Court of Virginia. It is also undisputed that the substantive issues now pending before this court with relation to vested rights, the legal effect of the two letters issued by the Zoning Administrator, and the legal effect of prior zoning actions as they impact vested rights are also before those Boards as part of the appeal. It is further apparently undisputed that, as part of the appeal before the Boards, the issue of CRA’s standing as an “aggrieved person” entitled to appeal a determination of the Zoning Administrator is also pending. {See, e.g., Paragraph 31 of the Fettler Complaint, as well as proffers and concessions of counsel in connection with argument on the Pleas in Bar.) What is disputed is the allegation of the Complaints that the two Boards should not be permitted to decide any of these issues for the reasons set forth in the Complaints. The issue then presented is whether, given the undisputed facts and assuming as true the remaining facts alleged in the Complaints for purposes of Demurrer, the Pleas in Bar should be granted and the Demurrers sustained.

The allegations of the Complaints with respect to grounds for not permitting the Board appeals to go forward fall into two general categories, lack of standing and procedural inadequacies.

Standing

Complainants argue that, because CRA has no standing to appeal the two Letters, or even to request the First Letter, it is not fair to the Complainants to permit the Boards to go forward with the hearings; this Court should instead hear and decide the standing issue.

I find this argument unpersuasive for three reasons.

First, one forum or another, the Court or the Boards, must decide the standing issues. The principal antagonists in the disputes over standing are CRA and the Complainants. Nothing set forth in the Complaints, other than conclusory allegations, states any reason why the Boards cannot decide these issues.

[420]*420Second, with respect to a number of issues relating to standing, the Boards are better suited to make the decisions. These are the bodies which enact, interpret, and enforce the zoning ordinances, and as such deal with the issues in this case, which are neither simple nor straightforward. For example, under the Zoning Ordinance the Board of Supervisors conferred upon the Zoning Administrator the authority to issue decision letters, which, as I understand it, are binding upon everyone if not appealed by someone. The First Letter is argued to be such a letter, though this argument is disputed. By issuing this letter to CRA at its request and advising CRA that it could appeal the letter if it wished, the Zoning Administrator arguably conferred standing of a sort, an action that one of the Complaints alleges he had no authority to take. Against this background, the standing issue may require determinations not only as to whether CRA has sufficient connection with the property to appeal the Letters, but also whether the First Letter was or was not a determination, and whether the first Letter was issued ill-advisedly and without authority, and, if so, whether it can or should be rescinded. The respective Boards have particular expertise in zoning matters and are particularly suited to decide such issues. With respect to the status of the First Letter, they may also have authority to take actions that this Court may not possess independent authority to take.

Procedure

Complainants allege that the procedures adopted by the Boards will not accord them a fair hearing on all issues, particularly including standing, and accordingly should not be permitted to go forward. This is a conclusion of law which I am not required to accept, even on Demurrer, and which I must reject. I note in this regard that the Complaints allege the existence of vested rights which have accrued under the very ordinance which they now say does not accord them a fair opportunity to be heard and, further, that these rights have vested in part as a result of the fact that no one appealed earlier governmental decisions, appeals which would have been heard under the same procedures they now complain of. The cases holding that this court need not, or should not, require parties to proceed with administrative remedies and administrative hearings, do so principally in cases where the complainant is adverse to the governmental entity in question and it is plain from the posture of the case that pursuit of further relief from the government will be fruitless.

The Complaints also allege that that there is a procedural omission which will deprive them of the right to appeal to this Court an adverse decision of the Board of Supervisors on the proffer interpretation. Assuming, without deciding, that this defect exists (as I must on Demurrer) and assuming that the offer of Spectrum not to oppose a declaratory judgment action will not result in effective judicial review, I do not find any constitutional [421]*421violation in this state of affairs, such that a hearing before the Board should be barred as a result. As mentioned above, the procedures for appeal are part and parcel of the zoning ordinance, and the Board of Supervisors has appropriate expertise to decide the issues before them. They are not a body adverse to the Complainants; from their Answer and their argument on the Pleas in Bar and Demurrers, it appears that they are neutral with respect to Complainants’ position on all matters except Complainants’ allegation that the Boards cannot give them a fair hearing, which both Boards deny.

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Cite This Page — Counsel Stack

Bluebook (online)
83 Va. Cir. 418, 2011 Va. Cir. LEXIS 134, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spectrum-healthcare-resources-inc-v-prince-william-county-board-of-vacckingwilliam-2011.