Tom Latta v. Chelan County

CourtCourt of Appeals of Washington
DecidedOctober 31, 2023
Docket39261-9
StatusUnpublished

This text of Tom Latta v. Chelan County (Tom Latta v. Chelan County) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tom Latta v. Chelan County, (Wash. Ct. App. 2023).

Opinion

FILED OCTOBER 31, 2023 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

TOM LATTA, ) No. 39261-9-III ) Appellant, ) ) v. ) ) CHELAN COUNTY, a Washington ) municipal corporation, ) ) Respondent. ) ) ) RIVERSIDE CABIN n/k/a RIVERSIDE ) CABIN AND LOFT LLC, a Washington ) UNPUBLISHED OPINION limited liability company, ) ) Appellant, ) ) v. ) ) CHELAN COUNTY, a Washington ) municipal corporation, ) ) Respondent. ) ) ) CEA, LLC - RIVERSIDE VACATION ) HOME, LLC, a Washington limited ) liability company, ) ) No. 39261-9-III Latta v. Chelan County

Appellant, ) ) v. ) ) CHELAN COUNTY, a Washington ) municipal corporation, ) ) Respondent. ) ) ) SIMS KELLY, LLC, a Washington ) limited liability company, ) ) Appellant, ) ) v. ) ) CHELAN COUNTY, a Washington ) municipal corporation, ) ) Respondent. )

PENNELL, J. — This is a consolidated appeal of land use decisions brought by four

owners of short-term rentals (STRs) 1 located in the city of Leavenworth’s Urban Growth

Area (UGA). 2 In 2021, each of the appellants applied for permits to continue their STR

1 STRs are, essentially, furnished dwellings rented as a single lodging unit by an owner or operator to tourists or other guests, for a fee, for periods of less than one month. See Chelan County Code 14.98.1691 (defining “short-term rental”); see also Leavenworth Municipal Code 21.90.030 (providing a similar definition for “transient accommodation and/or lodging”). 2 By interlocal agreement, Chelan County applies the city of Leavenworth’s zoning regulations to the Leavenworth UGA; thus, Leavenworth’s city government apparently zones for the UGA as well as within the city limits. See Clerk’s Papers at 400-01.

2 No. 39261-9-III Latta v. Chelan County

operations as existing nonconforming uses. Chelan County denied all four applications,

and the county’s hearing examiner affirmed. The STR owners 3 claim they are entitled

to nonconforming use permits because either their STRs qualify as preexisting lawful

uses or a 2021 county resolution provides broad amnesty for existing unpermitted STRs.

Both arguments are mistaken. We therefore affirm the hearing examiner.

FACTS AND PROCEDURAL BACKGROUND

The primary question on appeal is whether the appellants lawfully operated their

properties as STRs before the enactment of local zoning prohibitions. Each of the

appellants began their STR operations sometime after 1999. By way of background,

we note that the properties of all four appellants are located in the Leavenworth UGA

and all the properties are zoned as low-density residential.

The city of Leavenworth first adopted an ordinance prohibiting STRs (referred to

as “transient accommodation”) in low-density residential zones on December 12, 1989.

Ordinance 852 amended the portion of the Leavenworth Municipal Code (LMC) dealing

with permitted uses in low-density residential zones, and provided that structures in such

zones “not [be] used as a Bed and Breakfast or Transient Accommodation.” Clerk’s

Papers (CP) at 1459 (emphasis added). A “transient accommodation” was defined as

3 We alternatively refer to the appellants as either “appellants” or “STR owners.”

3 No. 39261-9-III Latta v. Chelan County

“a dwelling unit [4] or motel room regularly rented to transient guests with a less than

monthly rental period for each individual or group of guests.” Id. at 1458.

Ordinance 852 granted a one-year amortization period, allowing preexisting

transient accommodations or bed and breakfasts to temporarily continue operating.

After that one-year period, ostensibly ending in December 1990, the ordinance provided

that “any such non-conforming use shall be considered a zoning violation and shall be

discontinued.” Id. at 1459.

Ordinance 852’s prohibition on transient accommodations in Leavenworth’s

low-density residential zones was originally codified at former LMC 18.20.020

(repealed by Ordinance 1589), and has persisted within the code in the decades since. 5

4 “Dwelling unit” was defined as “one (1) room or rooms connected together constituting a separate, independent housekeeping establishment for owner occupancy, rent, or lease, to one individual family on a monthly or longer basis, and which is physically separated from any other rooms or dwelling units which may be in the same structure and which contains independent cooking and sleeping facilities.” Id. 5 In 2017, the city of Leavenworth adopted Ordinance 1542, which clarified rules for the permitting of a bed and breakfast. See CP at 7147-56. None of the appellants’ properties at issue here are operated as a “bed and breakfast,” which is defined separately from a “transient accommodation.” LMC 21.90.030. A bed and breakfast is the primary residence of the property owner, and the owner is required to live onsite during any guest’s stay. LMC 18.52.120; see also CP at 1458, 7150-51, 7153. Nothing in Ordinance 1542 altered the existing prohibition on transient accommodations in low-density residential zones. To the contrary, the ordinance “reiterat[ed] [the City’s] existing prohibition on the rental of entire dwellings as vacation rentals.” Id. at 7155 (emphasis added).

4 No. 39261-9-III Latta v. Chelan County

Since at least 2000, Chelan County has adopted Leavenworth’s land use designations for

the county’s unincorporated urban growth area around the city. See Chelan County Code

(CCC) 10.12.030. 6

Despite the prohibition on STRs in low-density residential zones beginning in the

early 1990s, enforcement appears to have been fairly lax. That began to change in recent

years. In April 2017, the city of Leavenworth stepped up enforcement actions against

STRs. See CP at 5468.

Chelan County subsequently established a task force to study the proliferation

of STRs. In 2021, after considering the task force’s recommendations, Chelan County

adopted an STR code. See CCC 11.88.290. The STR code’s purpose, in relevant part, is:

to promote the public health and safety by protecting year-round residents’ enjoyment of their homes and neighborhoods by minimizing the nuisance impact of short-term rentals on adjacent residences and by minimizing the detrimental impact of excessive short-term rentals on the affordable housing supply.

CCC 11.88.290(1)(C). In line with this purpose, the STR code places strict limits on

the number, location, and occupancy of STRs permitted in unincorporated Chelan

County, along with restricting the zones in which they can be operated, and providing for

6 First enacted in 2000, this provision adopts the city of Leavenworth’s comprehensive plan and associated maps as they apply to the unincorporated portion of the city’s UGA.

5 No. 39261-9-III Latta v. Chelan County

a permitting process for new and existing STRs. See CCC 11.88.290(2)(A)-(D), (3)-(4).

The STR code also expressly “adopts the cities of Cashmere, Chelan, Entiat,

Leavenworth, and Wenatchee land use regulations, development standards and land use

designations, as they apply to [STRs]” insofar as those cities’ codes already regulated

STRs in each city’s respective UGA. CCC 11.88.290(2)(C)(iv) (emphasis added).

The county’s STR code provides that “[a]ll” claims of existing nonconforming STRs

within a UGA are “subject to joint review by the county and the affected city.”

CCC 11.88.290(2)(C)(iv)(b) (emphasis added).

Following Chelan County’s adoption of its STR code, each of the four appellants

applied for permits to continue their STR operations.

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