West Bloomfield Twp v. United German American Rec Society

CourtMichigan Court of Appeals
DecidedFebruary 14, 2025
Docket366565
StatusUnpublished

This text of West Bloomfield Twp v. United German American Rec Society (West Bloomfield Twp v. United German American Rec Society) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
West Bloomfield Twp v. United German American Rec Society, (Mich. Ct. App. 2025).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

CHARTER TOWNSHIP OF WEST UNPUBLISHED BLOOMFIELD, February 14, 2025 2:06 PM Plaintiff-Appellee,

v No. 366565 Oakland Circuit Court UNITED GERMAN AMERICAN LC No. 2020-183280-CE RECREATIONAL SOCIETY, JOHN C. DWAN, and JUDY DWAN,

Defendants,

and

VICTOR VANMEERBEECK and LYNN VANMEERBEECK,

Defendants-Appellants, and

REAL PROPERTY LOCATED AT 2201 OAK PARK DRIVE, WEST BLOOMFIELD, MICHIGAN, 48324,

Defendant.

Before: BOONSTRA, P.J., and M. J. KELLY and MALDONADO, JJ.

PER CURIAM.

Defendants, Victor and Lynn Vanmeerbeek, appeal by right the trial court’s order granting summary disposition in favor of plaintiff, West Bloomfield Charter Township, pursuant to MCR 2.116(C)(10) (no genuine issue of material fact). We affirm.

-1- I. BACKGROUND

This case arises from plaintiff’s efforts to raze a cottage that defendants undisputedly constructed in violation of local zoning ordinances. At the center of this dispute is a small plot of land that is part of a 23-acre parcel on Cass Lake. The parcel has been owned by the United German American Recreational Society (UGARS) since 1937. Between 1937 and 1949, each member of UGARS was assigned a lot on the UGARS property, which held over two dozen small summer cottages; the VanMeerbeecks owned one of these cottages. Although the property was zoned R-10, single-family residential, UGARS and its members had a legal nonconforming use; therefore, they were able to lawfully use the property for recreational purposes as long as their use of the property otherwise complied with the West Bloomfield Township zoning ordinance.

The VanMeerbeecks owned an old 20-by-30-foot cottage that was not connected to a water or sewer system. In 2015, with permission of the UGARS board but without obtaining permits from plaintiff, the VanMeerbeecks demolished their cottage and began construction of a larger cottage. This new single-family residential structure was connected to a common well for water service and had a septic system. In 2018, plaintiff learned about the construction, conducted a site visit, and instructed the VanMeerbeecks to obtain an after-the-fact permit. However, plaintiff ultimately advised the VanMeerbeecks that the permit could not be issued because the construction impermissibly expanded an already nonconforming use. The VanMeerbeecks and UGARS were informed that they would need to apply for a zoning variance with the Zoning Board of Appeals (ZBA).

In 2020, plaintiff learned that the VanMeerbeecks were undertaking additional construction on their new cottage that included a drainage pipe that had resulted in flooding, an enclosed porch, a deck, a retaining wall, a fire pit near another cottage, a propane storage tank, a sidewalk, and a brick paver patio. Additionally, the VanMeerbeecks were occupying the new cottage on at least a part-time basis despite having never secured a certificate of occupancy, which is a violation of a zoning ordinance. At this point, plaintiff brought suit in the circuit court seeking demolition of the new cottage on the basis of zoning violations, public nuisance, and nuisance per se. The VanMeerbeecks put forth an equitable estoppel defense, asserting that plaintiff had a long history of issuing after-the-fact permits for significant construction projects on UGARS-owned land. The VanMeerbeecks challenged the township’s ability to enforce the zoning ordinance against them, asserting it would be highly unjust and inequitable to allow the township to do so under the circumstances of this case, particularly given that the township did not act in a swift and efficient manner when requiring the VanMeerbeecks to secure the necessary permits. The trial court, reasoning that the VanMeerbeecks failed to put forth evidentiary support for their equitable defense, granted summary disposition in favor of plaintiff. However, the court stayed the demolition of the property pending the exhaustion of the VanMeerbeecks’ appellate rights.

While not parties to this appeal, John and Judy Dwan were also defendants in this litigation due to construction on their UGARS-owned lot. The Dwans purchased their 20-by-30-foot cottage from Judy Dwan’s parents in 2015. This cottage was also intended to be a summer residence and was not connected to water or sewage facilities. When the zoning ordinance was enacted in 1966, the Dwan summer cottage was considered a legal nonconforming structure. The Dwans demolished their summer cottage without first securing a demolition permit, and they constructed a new single-family structure in its place without obtaining the necessary permits from the

-2- township. Although the Dwans applied for a building permit in September 2015, they did not complete the application process for personal reasons. The Dwans applied for an after-the-fact building permit, but it was not issued because the construction of the single-family structure altered and expanded a nonconforming use under the township zoning ordinance. The Dwans unsuccessfully sought a variance from the township ZBA that the circuit court affirmed. This Court denied the Dwans’ application for leave to appeal, as did our Supreme Court.1

II. DISCUSSION

The VanMeerbeecks argue that the trial court erred by concluding that there was no genuine issue of material fact regarding their affirmative defense of equitable estoppel. We disagree.

A. STANDARDS OF REVIEW

This Court reviews the trial court’s decision on a motion for summary disposition de novo. Maiden v Rozwood, 461 Mich 109, 118; 597 NW2d 817 (1999). A motion brought under MCR 2.116(C)(10) determines whether a complaint is factually sufficient, and our Supreme Court has explained the applicable standard of review:

In reviewing a motion for summary disposition brought under this subsection, a trial court considers affidavits, pleadings, depositions, admissions, and other evidence submitted by the parties in the light most favorable to the party opposing the motion. Where the proffered evidence fails to establish a genuine issue regarding any material fact, the moving party is entitled to judgment as a matter of law. [Quinto v Cross & Peters Co, 451 Mich 358; 547 NW2d 314 (1996) (citations omitted).]

This Court reviews the trial court’s application of the doctrine of equitable estoppel de novo. West American Ins Co v Meridian Mut Ins Co, 230 Mich App 305, 309; 583 NW2d 548 (1998).

B. OVERVIEW OF RELEVANT ZONING LAW

The parties do not dispute that the structures that existed on UGARS’ property when the West Bloomfield Township zoning ordinance was enacted in 1966 were considered nonconforming uses. “A prior nonconforming use is a vested right in the use of particular property that does not conform to zoning restrictions, but is protected because it lawfully existed before the zoning regulation’s effective date.” Heath Twp v Sall, 442 Mich 434, 439; 502 NW2d 627 (1993). MCL 125.3208(1) addresses nonconforming uses, providing in pertinent part:

(1) If the use of a dwelling, building, or structure or of the land is lawful at the time of enactment of a zoning ordinance or an amendment to a zoning

1 Dwan v West Bloomfield Charter Twp, unpublished order of the Court of Appeals, entered February 4, 2021 (Docket No. 355941), lv den 508 Mich 967 (2021).

-3- ordinance, then that use may be continued although the use does not conform to the zoning ordinance or amendment.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Reenders v. Parker
551 N.W.2d 474 (Michigan Court of Appeals, 1996)
Maiden v. Rozwood
597 N.W.2d 817 (Michigan Supreme Court, 1999)
Quinto v. Cross and Peters Co.
547 N.W.2d 314 (Michigan Supreme Court, 1996)
Heath Township v. Sall
502 N.W.2d 627 (Michigan Supreme Court, 1993)
West American Insurance v. Meridian Mutual Insurance
583 N.W.2d 548 (Michigan Court of Appeals, 1998)
Hughes v. Almena Township
771 N.W.2d 453 (Michigan Court of Appeals, 2009)
Kyocera Corp. v. Hemlock Semiconductor, LLC
886 N.W.2d 445 (Michigan Court of Appeals, 2015)
Charter Township of Lyon v. Marlene Hoskins
317 Mich. App. 482 (Michigan Court of Appeals, 2016)
Township of Williamstown v. Sandalwood Ranch LLC
927 N.W.2d 262 (Michigan Court of Appeals, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
West Bloomfield Twp v. United German American Rec Society, Counsel Stack Legal Research, https://law.counselstack.com/opinion/west-bloomfield-twp-v-united-german-american-rec-society-michctapp-2025.