Vieux Carre Property Owners, Residents & Associates, Inc. v. the City of New Orleans, Through Its Board of Zoning Adjustments and Director of Department of Safety and Permits

CourtLouisiana Court of Appeal
DecidedApril 6, 2022
Docket2021-CA-0687
StatusPublished

This text of Vieux Carre Property Owners, Residents & Associates, Inc. v. the City of New Orleans, Through Its Board of Zoning Adjustments and Director of Department of Safety and Permits (Vieux Carre Property Owners, Residents & Associates, Inc. v. the City of New Orleans, Through Its Board of Zoning Adjustments and Director of Department of Safety and Permits) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vieux Carre Property Owners, Residents & Associates, Inc. v. the City of New Orleans, Through Its Board of Zoning Adjustments and Director of Department of Safety and Permits, (La. Ct. App. 2022).

Opinion

VIEUX CARRE PROPERTY * NO. 2021-CA-0687 OWNERS, RESIDENTS & ASSOCIATES, INC. * COURT OF APPEAL VERSUS * FOURTH CIRCUIT THE CITY OF NEW * ORLEANS, THROUGH ITS STATE OF LOUISIANA BOARD OF ZONING ******* ADJUSTMENTS AND DIRECTOR OF DEPARTMENT OF SAFETY AND PERMITS

APPEAL FROM CIVIL DISTRICT COURT, ORLEANS PARISH NO. 2020-02429, DIVISION “J” Honorable D. Nicole Sheppard, ****** Judge Daniel L. Dysart ****** (Court composed of Judge Roland L. Belsome, Judge Daniel L. Dysart, Pro Tempore Judge Madeline Jasmine)

Andrew K. Jacoby LAW OFFICE OF ANDREW JACOBY, LLC 2118 Pakenham Drive Chalmette, LA 70043

COUNSEL FOR PLAINTIFF/APPELLANT

Shawn Lindsay Daniel T. Smith Churita H. Hansell Donesia D. Turner Sunni J. LeBeouf CITY ATTORNEYS 1300 Perdido Street Suite 5E03 New Orleans, LA 70112

COUNSEL FOR DEFENDANT/APPELLEE

Robert J. Ellis, Jr. R.J. ELLIS LAW FIRM 650 Poydras Street Suite 2615 New Orleans, LA 70130 Salvador I. Bivalacqua Will C. Griffin GALANTE & BIVALACQUA LLC 650 Poydras Street Suite 2615 New Orleans, LA 70130

COUNSEL FOR INTERVENOR/APPELLEE CHARTERS CAFÉ, LLC/WILLIE’S CHICKEN SHACK

AFFIRMED APRIL 6, 2022 DLD RLB MJ This is an appeal by plaintiff-appellant, Vieux Carré Property Owners,

Residents & Associates, Inc. (“VCPORA”), of the district court’s August 18, 2021,

judgment denying a Petition for Writ of Certiorari to Review the Ruling of the City

of New Orleans Board of Zoning Adjustments (“BZA”) and the Decision of

Director of Department of Safety and Permits to issue a “standard restaurant”

occupational license to Charters Café L.L.C., d/b/a Willie’s Chicken Shack

(“Willie’s”). For the following reasons, we affirm the district court’s judgment.

FACTUAL AND PROCEDURAL BACKGROUND

On August 16, 2019, the Director of the Department of Safety and Permits

of Orleans Parish, Zachary Smith, issued an occupational license to Willie’s for the

property located at 601 Chartres Street in the French Quarter. VCPORA opposed

the Director’s decision on grounds that the business entity had been improperly

classified as a “standard restaurant” rather than a “fast-food” restaurant. Because

601 Chartres Street is zoned as VCC-2 under the Comprehensive Zoning

Ordinances (“CZO”) of Orleans Parish, standard restaurants are allowed to operate

1 at the location while fast-food restaurants are impermissible. On February 10,

2020, the BZA held a public hearing on VCPORA’s appeal of Director Smith’s

decision. After consideration of the facts and arguments of all parties, the BZA

determined that the approval standard for appeals had not been met and

accordingly denied VCPORA’s appeal and upheld Director Smith’s decision to

issue the standard restaurant license. On March 11, 2020, VCPORA filed a

Petition for Writ of Certiorari to Review the Ruling of the City of New Orleans

Board of Zoning Adjustments and the Decision of Director of Department of

Safety and Permits in the district court, seeking the reversal of the BZA’s ruling as

well as the revocation of Willie’s occupational license. By judgment dated August

18, 2021, the district court ruled in favor of the City (BZA) and Intervenor

(Willie’s), denying VCPORA’s Petition and dismissing the matter with prejudice.

VCPORA timely filed an appeal of this judgment, contending that the district court

erred in denying the Petition for Judicial Review.

STANDARD OF REVIEW

District courts have original jurisdiction to review decisions of an

administrative body, such as the BZA. Dupuis v. City of New Orleans through

Zoning Bd. of Zoning Adjustments, 2017-0052, p. 2 (La. App. 4 Cir. 8/2/17); 224

So.3d 1046, 1048. See also, e.g., Gertler v. City of New Orleans, 346 So.2d 228,

233 (La. App. 4 Cir. 1977); River Oaks–Hyman Pl. H. Civ. A. v. City of New

Orleans, 281 So.2d 293 (La. App. 4 Cir., 1973)(“when a district court reviews a

decision of an administrative body, it is exercising ‘exclusive original

jurisdiction’”) (citations omitted). The Courts of Appeal, then, exercise appellate

jurisdiction over district court decisions concerning the review of decisions of

zoning boards. Dupuis, 17-0052, p. 3, 224 So.3d at 1049. Thus, “[a] reviewing

2 [appellate] court does not consider whether the district court manifestly erred in its

findings, but whether the zoning board acted arbitrarily, capriciously or with any

calculated or prejudicial lack of discretion.” King v. Caddo Par. Com’n, 97-1873,

pp. 14-15 (La. 10/20/98), 719 So.2d 410, 418.

Because zoning laws and decisions fall within the ambit of a municipality’s

legislative powers, the decisions of zoning boards are presumed to be valid by

reviewing appellate courts. See, Vieux Carré Prop. Owners v. City of New

Orleans, 14-0825, pp. 5-6 (La. App. 4 Cir. 4/15/15), 216 So.3d 873, 877, writ

denied sub nom., 15-1147 (La. 9/18/15), 178 So.3d 149 (Citations omitted).

However, this presumption of validity is rebuttable; and a party aggrieved by a

decision of the BZA is entitled to judicial review through a writ of certiorari. Id.

14-0825, p. 6, 216 So.3d at 877. “The purpose of certiorari review…of decisions

of boards and quasi-judicial tribunals is to ‘determine whether jurisdiction has been

exceeded, or to decide if the evidence establishes a legal and substantial basis for

the Board’s decision.’” Esplanade Ridge Civic Ass'n v. City of New Orleans, 13-

1062, p. 3 (La. App. 4 Cir. 2/12/14); 136 So.3d 166, 169, quoting Elysian Fields,

Inc. v. St. Martin, 600 So.2d 69 (La. App. 4 Cir. 1992).

The presumption is sufficiently rebutted if the reviewing court determines

that the evidence fails to establish a legal and substantial basis for the decision or

that the BZA has exceeded its jurisdiction and acted in an arbitrary and capricious

manner. Id. (internal quotation and citation omitted). For purposes of review of a

zoning decision, “[t]he terms ‘arbitrary and capricious’ mean willful and

unreasoning action, absent consideration and in disregard of the facts and

circumstances of the case.” Toups v. City of Shreveport, 10-1559, p. 3, (La.

3/15/11); 60 So.3d 1215, 2017 (citation omitted). “It is only when an action of a

3 zoning commission is found on judicial review to be palpably unreasonable,

arbitrary, [or] an abuse of discretion…that such action will be disturbed.” City of

Baton Rouge/Par. Of E. Baton Rouge v. Myers, 13-2011, p. 6 (La. 5/7/14); 145

So.3d 320, 327-28 (citation omitted). “However, when there is room for two

opinions, an action is not arbitrary or capricious when exercised honestly and upon

due consideration, even though it may be believed an erroneous conclusion has

been reached.” Toups, 10-1559, pp. 3-4, 60 So.3d at 1217 (citation omitted).

“On appeal, ‘[t]he aggrieved party bears the burden of showing that the BZA

decision is arbitrary, capricious, or manifestly erroneous in light of substantial

evidence in the record.’” Dupuis, 17-0052, p. 5, 224 So.3d at 1049 (quoting Vieux

Carré Prop. Owners, 14–0825, p. 7, 216 So.3d at 877).

DISCUSSION

Appellant assigns four errors. First, Appellant argues that the BZA and

Director Smith erred by issuing a license before taking the “legally mandated hard-

look” at the evidence. Secondly, Appellant alleges that the BZA and Director

Smith erred by issuing a license in violation of the “holding bar” ordinance. Third,

Appellant argues that the BZA and Director Smith erred by issuing Willie’s a

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Related

Elysian Fields, Inc. v. St. Martin
600 So. 2d 69 (Louisiana Court of Appeal, 1992)
River Oaks-Hyman Pl. H. Civ. A. v. City of New Orleans
281 So. 2d 293 (Louisiana Court of Appeal, 1973)
Graubarth v. French Market Corp.
970 So. 2d 660 (Louisiana Court of Appeal, 2007)
King v. Caddo Parish Com'n
719 So. 2d 410 (Supreme Court of Louisiana, 1998)
Gertler v. City of New Orleans
346 So. 2d 228 (Louisiana Court of Appeal, 1977)
Esplanade Ridge Civic Ass'n v. City of New Orleans
136 So. 3d 166 (Louisiana Court of Appeal, 2014)
City of Baton Rouge/Parish of East Baton Rouge v. Myers
145 So. 3d 320 (Supreme Court of Louisiana, 2014)
Vieux Carre Property Owners v. City of New Orleans
216 So. 3d 873 (Louisiana Court of Appeal, 2015)
Dupuis v. City of New Orleans ex rel. Zoning Board of Zoning Adjustments
224 So. 3d 1046 (Louisiana Court of Appeal, 2017)
Toups v. City of Shreveport
60 So. 3d 1215 (Supreme Court of Louisiana, 2011)

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Vieux Carre Property Owners, Residents & Associates, Inc. v. the City of New Orleans, Through Its Board of Zoning Adjustments and Director of Department of Safety and Permits, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vieux-carre-property-owners-residents-associates-inc-v-the-city-of-lactapp-2022.