Wihbey v. Zoning Board of Appeals (Dissent)

CourtSupreme Court of Connecticut
DecidedJuly 1, 2024
DocketSC20839
StatusPublished

This text of Wihbey v. Zoning Board of Appeals (Dissent) (Wihbey v. Zoning Board of Appeals (Dissent)) is published on Counsel Stack Legal Research, covering Supreme Court of Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wihbey v. Zoning Board of Appeals (Dissent), (Colo. 2024).

Opinion

************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopin- ion motions and petitions for certification is the “offi- cially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Jour- nal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************ Page 0 CONNECTICUT LAW JOURNAL 0, 0

2 ,0 0 Conn. 0 Wihbey v. Zoning Board of Appeals

McDONALD, J., with whom ECKER, J., joins, dis- senting. This appeal centers on whether the zoning regu- lations governing a residential neighborhood designated for ‘‘single-family’’ homes permit the short-term occu- pancy of those structures by transient travelers.1 This court has recognized that ‘‘[t]he purpose of zoning is to serve the interests of the community as a whole . . . .’’ (Emphasis added.) Malafronte v. Planning & Zoning Board, 155 Conn. 205, 212, 230 A.2d 606 (1967). Today, the majority of this court discounts both the importance of zoning regulations to the interests of the community as a whole and the plain meaning of the terms included in the applicable residential zoning regulations and holds that the short-term occupancy of a single-family home by transient travelers, which undermines the very purpose of the applicable zoning regulations, neverthe- less is permitted by those regulations. The plaintiff, Frances Wihbey, was ordered by the zoning enforcement officer (zoning officer) of the Pine Orchard Association (POA), an incorporated borough and municipal subdivision of the town of Branford, to cease and desist from engaging in the short-term rental of a single-family property the plaintiff owned in the POA. The plaintiff appealed to the defendant, the Zoning Board of Appeals of the Pine Orchard Association (board), which upheld the cease and desist order. The plaintiff then appealed from the board’s decision to the trial court, which reversed that decision. The board and the intervening defendants, Michael B. Hopkins and Jacqueline C. Wolff,2 appealed, on the granting of certifi- The Vrbo terms and conditions expressly refer to the party paying for 1

use of the property as a ‘‘traveler.’’ Vrbo, Terms and Conditions (last updated July 6, 2023), available at https://www.vrbo.com/lp/b/terms-of-service?msockid= 1592f2630ba46bf63156e0c10a5a6a5e (last visited July 26, 2024). 2 The intervening defendants are owners of real property that abuts the plaintiff’s property. For convenience, I hereafter refer to the board and the intervening defendants collectively as the defendants. 0, 0 CONNECTICUT LAW JOURNAL Page 1

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cation, from the trial court’s judgment to the Appellate Court, which affirmed in part and reversed in part the trial court’s judgment. Wihbey v. Zoning Board of Appeals, 218 Conn. App. 356, 359, 396, 292 A.3d 21 (2023). This court granted certification to determine whether short- term occupancy of a single-family dwelling by transient travelers constitutes a permissible use of the subject property under the 1994 POA zoning regulations (1994 regulations).3 See Wihbey v. Zoning Board of Appeals, 346 Conn. 1019, 1019–20, 292 A.3d 1254 (2023). Because I conclude that the short-term occupancy of the plain- tiff’s property by transient travelers was impermissible under the 1994 regulations, I would reverse in part the judgment of the Appellate Court. Accordingly, I respect- fully dissent. In 2005, the plaintiff purchased property in the POA. The property consists of a single-family home subject to the POA’s zoning regulations. Since purchasing the property, the plaintiff has consistently allowed travelers to book the property on a short-term basis, typically for periods of three days to one week, on the Vrbo4 website. Importantly, in the last ten years, these tran- sient travelers have never stayed at the property for more than thirty days at a time.5 3 Although the POA refers to the 1994 regulations collectively as the 1994 Pine Orchard Association Zoning Ordinance, I refer to this body of regula- tions as regulations in the interest of simplicity. 4 Vrbo is a web-based platform that allows property owners to connect with potential short-term travelers. Vrbo, Terms and Conditions (last updated July 6, 2023), available at https://www.vrbo.com/lp/b/terms-of-service?msockid= 1592f2630ba46bf63156e0c10a5a6a5e (last visited July 26, 2024) (stating that ‘‘[t]he [s]ite is a [v]enue and [w]e are [n]ot a [p]arty to any [r]ental [a]greement or other [t]ransaction [b]etween [u]sers of the [s]ite’’). Vrbo does not provide ‘‘rental agreements,’’ but property owners are permitted to separately enter into these agreements with renters. See Vrbo, Upload Your Rental Agree- ment, available at https://help.vrbo.com/articles/How-to-upload-my-rental- agreement (last visited July 26, 2024) (‘‘[r]ental agreements are optional documents you can add to your listing to expand on your house rules and set expectations with guests’’). 5 A period of less than thirty days is widely considered transient and insufficient to establish an individual’s dwelling. See, e.g., General Statutes Page 2 CONNECTICUT LAW JOURNAL 0, 0

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Relevant to this appeal, the 1994 regulations state that the purpose of the regulations is to ‘‘provid[e] a comprehensive plan which will promote the health, safety, and general welfare of the community’’ and that the regulations ‘‘shall be made with reasonable consid- eration as to the character of the community . . . .’’ Pine Orchard Assn. Zoning Regs., § I (1994). Section IV (4.1) of the 1994 regulations, which lists the permitted uses of properties, provides one permitted use to be as ‘‘[a] single-family dwelling’’; id., § IV (4.1); which is defined in § XIII as ‘‘[a] building designed for and occu- pied exclusively as a home or residence for not more than one family.’’ Id., § XIII. Section XIII of the 1994 regulations further defines ‘‘family’’ as ‘‘[o]ne or more persons related by blood, marriage or adoption, and in addition, any domestic servants or gratuitous guests. A roomer, boarder or lodger, shall not be considered a member of a family.’’6 Id. The 1994 regulations do not expressly permit the renting of single-family homes but do provide that ‘‘[a] sign not more than five square feet in area when placed in connection with the sale, rental, construction or improvement of the premises and for no other purpose’’ is permitted. (Emphasis added.) Id., § IV (4.4). In 2018, the POA adopted recommended amendments to its 1994 regulations, which included a specific provi- § 47a-2 (c) (1) (‘‘[o]ccupancy in a hotel, motel or similar lodging for less than thirty days is transient’’); Americans with Disabilities Act Accessibility Guidelines, 28 C.F.R. pt. 36, app.

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