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HomeMy WebLinkAbout941668.tiff w Cv1 T U: - DISTRICT COURT OF WELD COUNTY, STATE OF COLORADO Case No . 94-CV-203 Division IV BRIEF IN RESPONSE TO PLAINTIFFS ' MOTION FOR SUMMARY JUDGMENT AND BRIEF PURSUANT TO RULE 106 AND DEFENDANTS ' CROSS-MOTION FOR SUMMARY JUDGMENT ON PLAINTIFFS ' DECLARATORY JUDGMENT CLAIM IVAR LARSON AND DONNA LARSON, Plaintiffs , v. THE BOARD OF COUNTY COMMISSIONERS OF WELD COUNTY, George Baxter, Connie Harbert, Dale Hall, Barbara Kirkmeyer, Bill Webster, County Commissioners, Defendants . COMES NOW the Defendants, by and through their attorney, the Assistant of Bruce T. Barker, below-named, and submit the following Brief in Response to Plaintiffs ' Motion for Summary Judgement and Brief Pursuant to Rule 106 and Defendants ' Cross-Motion for Summary Judgment on Plaintiffs ' Declaratory Judgment Claim: I . STATEMENT OF FACTS Plaintiffs are the owners of real property in part of Section 5 , Township 4 North, Range 68 West of the 6th P .M. , Weld County, Colorado, located approximately one-quarter mile west of the intersection of Weld County Road 5 and State Highway 60 . (Vol . 1, pg. 137 ; Vol . 2 ) The parcel contains 25 acres , approximately, of 1 91//‘ /91 99EO irrigated farm land which was zoned and still is zoned A - Agricultural Zone under the Weld County Zoning Ordinance ( "Zoning Ordinance" ) . The applications for Mountain View Estates 1 and Mountain View Estates 2 (collectively, "Mountain View" ) were submitted for two separate "minor subdivisions" pursuant to the Weld County Subdivision Ordinance # 173-A ( "Subdivision Ordinance" ) . The parcels were originally subdivided in 1974 pursuant to a recorded exemption process under the existing County subdivision regulations . (Vol . 1 , pg. 199 , Exh. 42; Vol . 2, pg. 499 ) The Plaintiffs made two applications for adjacent previously divided properties for two minor subdivisions totaling 9 lots . A single application for a minor subdivision was unavailable because of a limit to six lots per minor subdivision. The applicants were only able to apply without first rezoning the property because the Zoning Ordinance allowed minor subdivisions in the A - Agricultural Zone District as creating legal lots for a three month period between December 29 , 1992 and March 8 , 1993 . Zoning Ordinance #89- X and 89-Y, Section 31 .2 .2 (Vol . 7-A and 7-B) . The applicants made application for the sketch plan for Mountain View, an adminis- trative review process (Section 5 , Subdivision Ordinance # 173-A) , immediately prior to the March 8, 1993 change in the Zoning Ordinance, as well as for another pair of minor subdivisions known as Whitetail Acres I & II ( see Case # 94-CV-172) , but did not 2 actually proceed with the platting process until November 4 , 1993 . The applications for the Mountain View plats were determined to be complete and the review process commenced by staff November 18 , 1993 . (Vol . 1, pg. 136 ; Vol . 2 , pg. 437 ) Department of Planning Services staff reviewed the applications and recommended denial based upon their determination that the applicants had not met their burden to show compliance with Section 4 . 5 . 9 of the Subdivision Ordinance. (Vol . 1 , pg. 0137, Exh. 5; Vol . 2 , pg. 438, Exh. 5) [Note that the criteria for review by the Planning Commission in the Subdivision Ordinance Section 4 . 5 . 9 are the same as those for review by the Board of County Commissioners which are found at Section 4 . 5 . 16 . ] The matter was then heard by the Weld County Planning Commission ( "Planning Commission" ) (Vol. 1 , pgs . 152-153 and 231- 239 ) following continuances requested by the plaintiffs . The Planning Commission unanimously recommended denial to the Board of County Commissioners ( "Board" ) . (Vol . 1, pg. 232-234 ; Vol . 2 , pg. 516-518) The matter was ultimately heard by the Board, again after additional continuances from December 31, 1993 to January 4 , 1994 , on March 30, 1994 . (Vol . 1, pgs . 152-153; Vol . 2 , pgs . 453-454 ) The Board unanimously denied the application and incorporated the recommendation of the Planning staff and the Planning Commission. (Vol . 1, pgs . 2-4 ; Vol . 2, pgs . 340-342) The parties had agreed to conduct hearings on the two Mountain View proposals simultaneously 3 so that there is only one transcript (Vol . 3 ) and the written records are, for the most part, identical (Vol . 1 and 2 ) . The Comprehensive Plan is divided into various sets of goals and policies . Because of the current zoning in the area around the Mountain View proposals, the agricultural goals and policies were part of the review considerations . (Vol . 1, pgs . 2-4 ; Vol . 2 , pgs . 340-342 ) Had the area already been rezoned, the agricultural policies would not have been an issue. The agricultural policies can be capsulized as minimizing the conversion of agricultural land to other uses especially where, as here, the land is prime agri- cultural land. The Board denied the application on a number of grounds , including a failure to comply with the Comprehensive Plan. However, the Board also found, pursuant to Section 4 . 5 . 16 of the Subdivision Ordinance, that the applicants failed to address concerns regarding the suitability of the soils for urban develop- ment and the creation of an additional access onto Colorado Highway 60 . II . ANALYSIS OF FACTUAL BASIS FOR DECISION There is substantial evidence in the record supporting the findings of non-compliance with the Comprehensive Plan policies in an agri- culturally zoned district. (Resolution of Board, Vol . 1 , pg. 2 and Vol . 2 , pgs . 340-342, Sections 1 .a, 1 .b, 1 .c, 1 .e, 1 . f) There was 4 substantial opposition principally related to the impacts on agri- culture to the proposals . Examples : Vol . 1, pgs . 253-332 ; Vol . 1 , pg. 188-193; Vol . 2 , pgs . 397-403 and 503-512 ; Vol . 3, pg. 63, line 7 through pg. 65, line 24 ; pg. 97 , line 41 through pg. 98, line 14 ; and pg. 101, line 15 through pg. 108, line 9 . The lots proposed to be created in Mountain View clearly are not for agricultural purposes , but are for uses incidental to residential . The proposed covenants (Vol . 1, pgs . 79 ; Vol . 2 , pg. 408) prohibit the use of the lots for any uses except for residential and related purposes ( Section 2 . 01 ) . Section 2 . 03 of the Covenants requires a minimum square footage of 1,400 square feet and the number of animals allowed to be kept on the property, Section 2 . 06 , are much more restrictive than allowed in the agricultural zone of the Zoning Ordinance. ( Section 31 . 5 .4 and Definition of Animal Unit, Zoning Ordinance) . The lots average less than three acres in size and are allowed only two large animals per lot; agricultural zoning would allow four large animals per acre. Section 2 . 16 of the Covenants limits the agricultural uses to producing a garden and/or orchard "unless proper conserva- tion measures are utilized to prevent blowing dust and soil erosion. " The Mountain View proposal clearly is intended to change the character of the use from agricultural to residential and the Board had substantial evidence that this change was not consistent with the comprehensive plan goals and policies , a finding 5 Plaintiffs do not challenge factually in their brief . Plaintiffs overstate some of the facts which they cite as supporting their position. The City of Loveland took a no comment position, but did respond and as such should not be viewed as supportive of the Subdivisions . The letter received from the City of Loveland speaks for itself (Vol . 1, pg. 466 ) . The Plaintiffs attempt to make the area surrounding the subdivisions out to be a residential neighborhood but the testimony and photos introduced IP by the neighbors make it clear it is not. It is primarily a rural setting with a minimal number of residences . (Vol . 1, pgs . 203- 217 , which are prints of slides submitted as Exhibit 46 and described in the Transcript (Vol . 3 , pg. 109 , line 24 through pg. 112 , line 25) ) . The field checks (Vol . 1, pg. 179 ; Vol . 2 , pg. 480) show the land use on all sides as agricultural . The evidence overwhelmingly demonstrates the rural agricultural use of the area and residents of the area testified that the majority of the houses in the area are old and were created as part of large farming operations . (Vol . 1, pg. 197 ; Vol . 2 , pg. 497 , Exh. 40; Vol . 3, pg. 83 , lines 4-22) The Board also found that new accesses were created on State Highway 60 in contravention of Section 4 . 5 . 16 . 11 of the Subdivision Ordinance # 173 . Prior to this Mountain View minor subdivision ;..c proposal , the area of the proposed subdivisions and additional two 6 dwellings to the east of the proposed subdivisions were served by a joint access . A dispute arose with the owners of property to the east of the proposed Mountain View subdivisions as to the right to use the access which lies 30 ' on either side of the shared property line and was based upon a upon an easement dated March 24 , 1974 , but not recorded until May 19 , 1982 (Vol . 1, pg. 198, Exh. 41) . The Colorado Department of Transportation (CDOT) had granted a new highway access permit on November 1, 1993, but that permit presumed there was an agreement on the joint access . There was no clarifi- cation of the use of the joint access, although the issues were identified in a memo of December 13, 1993 (Vol . 1, pg. 170) identifying the need for clarification in order that joint access could be considered as adequate access for the subdivisions . CDOT, in a letter of December 23, 1993 by Theresa Jones (Vol . 1 ; Vol . 2 , pgs . 462-464 ) , discussed these issues and indicated that the access permit of November 1 , 1993 presumed the use of the joint access and would have to be revoked. As a result, the Plaintiffs asked for a postponement of a hearing before the Planning Commission because the road was to be moved. (Vol . 1, pg. 461, Exh. 16 ) The Plaintiffs , however, still continue to claim an interest in the joint access which serves the two lots to the east of the proposed Mountain View subdivisions . (Vol . 1 , pg. 195; Transcript, Vol . 3 , pg. 146 , line 23 through pg. 147 , line 5 ) . 7 III . ARGUMENT A. Standard of Review 1 . Rule 106 (a) (4 ) , C.R.C.P. Standard A Rule 106 (a) (4 ) , C.R.C. P. , proceeding provides only very limited scope of review by the District Court of a decision of an inferior tribunal . The appropriate standard to be applied to a judicial review of the record is limited to a determination as to whether the Board of County Commissioners, as the "inferior tribunal" , exceeded its jurisdiction or has abused its discretion. Clary v. County Court, 651 P.2d 908 (Colo . App. 1982 ) ; Ragsdale v. County Court, 39 Colo. App. 341, 567 P. 2d 817 ( 1977 ) . The Court must uphold the decision of the Board unless there is no competent evidence to support the decision. Corper v. City and County of Denver, 191 Colo . 252 , 552 P. 2d 13 ( 1976 ) ; Ford Leasing Development Company v . Board of County Commissioners, 186 Colo . 418, 528 P.2d 237 ( 1974 ) ; Coleman v. Gormley, 748 P . 2d 361, 364 (Colo . App. 1987 ) . It is the Plaintiffs ' burden, as parties challenging the Board' s action, to establish invalidity of the Board' s action beyond a reasonable doubt. Corper, 552 P . 2d at 15; Coleman, 748 P . 2d at 364 . The reviewing Court cannot substitute its own judgment for that of the lower tribunal if there is any competent evidence to support the lower tribunal ' s decision. The State Civil 8 Service Commission v. Hazlett, 119 Colo. 173 , 201 P . 2d 616 ( 1948) . The interpretation by public officials such as the Board of County Commissioners charged with reading their own legislative enactments is entitled to deference by any reviewing court. Corper v. City and County of Denver, 36 Colo. App. 118, 536 P. 2d 874 ( 1975) , aff 'd. 191 Colo. 252, 552 P.2d 13; Roundup Foundation, Inc . v. Board of Adjustment of the City and County of Denver, 626 P. 2d 1154 , 1157 (Colo. App. 1981) ; Schneider v. Industrial Commission of the State of Colorado, 624 P . 2d 371 (Colo. App. 1981) This deference extends to zoning staff who are vested with the day-to- day administration of legislative enactments . Neighbors for Better Approach v. Nepa, 770 P. 2d 1390 , 1392 (Colo. App. 1989 ) . Deference to the Board' s interpretation is especially compelling where the Planning Commission, planning staff, and Board all applied the same interpretation to the County enactments . 2 . Standard for Reviewing Validity of Legislative Enactments Plaintiffs have attacked the validity of the process of adoption of the Comprehensive Plan and provisions within the Subdivision Ordinance which require the consideration of the Comprehensive Plan pursuant to a claim for declaratory relief . Legislative enactments such as the Subdivision Ordinance and the Comprehensive Plan of Weld County are presumed to be valid. A 9 party challenging the validity of a county ordinance, including challenges based on lack of constitutionality, assumes the burden of proving the asserted invalidity beyond a reasonable doubt. Sellon v. City of Manitou Springs , 745 P. 2d 229 , 232 (Colo. 1987 ) , Board of Jefferson County Commissioners v. Mountain Air Ranch, 563 P. 2d 341, 344 (Colo. 1977 ) . The ordinance is a legislative enactment and is presumed valid. Tri-State Generation and Transmission Company v. the City of Thornton, 647 P . 2d 670, 677 (Colo. 1982) ; Sundance Hills Homeowners Association v. Board of County Commissioners, 188 Colo. 321, 534 P.2d 1212 , 1217 ( 1975) . Ford Leasing Development Company v. Board of County Commissioners of Jefferson County, 528 P . 2d 237 , 241 (Colo . 1974 ) . The Plaintiffs have a substantial burden to overcome, which they have not done, to show that the Comprehensive Plan has been adopted improperly or that the Subdivision Ordinance incorporates provisions contrary to law. B. Analysis 1 . The Comprehensive Plan Has Been Adopted and Certified in Accordance With Statute. The Comprehensive Plan has been adopted by the Planning Commission by action of November 16 , 1986 , with subsequent amend- ments on June 10 , 1987 and January 21, 1992 (Vol . 6 ) and each such 10 action certified under signature of the Secretary to the Board of County Commissioners . The action by the Planning Commission appears to meet the requirements of C.R. S. §§ 30-28-108 and 109 . The Board then adopted the Comprehensive Plan pursuant to Ordinance 147, 147-A, and 147-B in a manner which conforms to the require- ments of the Weld County Home Rule Charter. It should also be noted that the record of the Planning Commission action was obtained from the records of the Board. 2 . Comprehensive Plan Was Adopted Properly in Light of the Weld County Home Rule Charter Weld County is a Home Rule County, under a charter adopted effective January 1 , 1976 (hereinafter referred to as "Charter" ) . County Home Rule exists pursuant to Article XIV, Section 16 of the Colorado Constitution. This provision authorizes the electors of each county to adopt a Home Rule Charter estab- lishing "the organization and structure of county government . . . The State Legislature has adopted two principal statutory provisions specifically dealing with county home rule. The provisions of C . R. S . §§ 30-11-501, et seq, are primarily procedural and structural and deal with the process to enact, amend, and repeal a charter but do contain specific language granting substan- tive powers under a Home Rule Charter. C.R. S . § 30-11-501 allows 11 the county electors by majority vote, to "establish the organiza- tion and structure of county government . . . " . C.R.S. Section 30- 11-511 requires that home rule counties provide mandatory county function services and that the county may exercise permissive powers except as otherwise prohibited or limited by the County Charter or Constitution. Consistent with the constitutional provision, the statute gives free reign to the electors of the county to create a structure for carrying out the county functions by means of different officers than are designated by statute for statutory counties . C.R. S . Section 30-11-511 states : "Any power, function, service or facility vested by statute in a particular county officer, agency, or board, including the Board of County Commissioners, may be exercised or performed within a Home Rule County by such county officer, agency, or board, or by any other county officer, agency, or board designated in the Home Rule Charter. " The "substantive" Home Rule Powers Act, C .R.S. § 30-35-201, also specifically mentions as a county power, at subsection (40) , the powers of planning and zoning pursuant to Article 28 of C.R.S . of Title 30 . However, it must be read in conjunction with C. R.S . Section 30-35-301, which sets forth a procedure and a duty to: "make and publish, from time to time, ordinances, not inconsistent with the laws of the state, for carrying into effect or discharging the powers and duties conferred by this article and as seems necessary and 12 proper to provide for the safety, preserve the health, promote the prosperity, and improve the morals, order, comfort and convenience of such county and the inhabitants thereof" . The exercise of county powers under a Home Rule Charter by means of an ordinance process is not inconsistent with the subdivision, planning and zoning powers found in Title 30 , Article 28 , in general , nor the comprehensive planning powers specifically found at C.R. S . §S 30-28-106 to 109 . The Home Rule County procedures do not change the authority of a County to adopt a Comprehensive Plan but do change the procedure by which a Comprehensive Plan is adopted and implemented. The Charter centralizes the county powers in the Board of County Commissioners . This structure requires that the Board of County Commissioners should be the adopting body for the Compre- hensive Plan. Article III , Section 3-8 (2 ) of the Charter provides that "it (Board of County Commissioners] shall exercise all powers of the county to determine policy and to enact legislation. " Article III , Section 3-8 (4) provides without limitation that the powers and duties of the Board shall include under (b) the power to: "Enact legislation including such means of enforcement thereof as shall be authorized by law, and otherwise formally promulgate county policy. " 13 The Board also has the power under Article III , Section 3-8 ( 4 ) (h) to designate itself to perform the functions and exercise the process of any other commission as may be required by state law unless prohibited by state law or Charter. The Board' s position of primacy within Weld County government is not disturbed by the Home Rule Charter section regarding the Planning Commission found at Article IV Section 4-4 (a) (3) . In particular Article IV, Section 4- 4 (A) (4) (c) provides that all decisions of the Planning Commission are subject to appeal and review by the Board and 4 (b) authorizes the Planning Commission to act as directed by law and as directed by the Board. This centralized approach is consistent with the adoption by the Board of the Comprehensive Plan. The Charter provisions regarding adoption of legislation and policies support the view that the Comprehensive Plan had to be adopted by the Board in order to be effective. Article III , Sections 3-8 ( 2 ) and (4 ) (b) require the Board to enact legislation and otherwise formally promulgate county policy and that legisla- tion must be in the form of an ordinance . See Article III , Section 3-14 of the Charter. The Charter, which makes Weld County unique, requires the Board to formally promulgate County policy which was done in the adoption of the Comprehensive Plan. 14 The nature of the Charter has previously been reviewed in relation to the Personnel Policy of the Sheriff by the Weld District Court. The decision of Judge Behrman was adopted as a decision of the Colorado Court of Appeals in the Board of County Commissioners v. Andrews, 687 P.2d 457 (Colo. App. 1984 ) . The decision sets forth the legislative history of county home rule in Colorado and in Weld County and sets forth the dual nature of the constitutional legal basis for county home rule. It should be noted that the case was at issue before the adoption of C.R.S . § 30-35-201 . The Court of Appeals, quoting District Judge Behrman, stated: "the Home Rule Counties are given broad discretion in the area of structure-creating of a frame of government, designating county official , and establishing their relative duties within the county government. They are given much less freedom in determining what functions they may choose to have their county government perform. Until recently this area of county government function has been no broader in Home Rule County' s than in non Home Rule County' s . " 687 P. 2d at 459 . Distinguished from statutory counties in Sealy v. Board of County Commissioners, 771 P. 2d 21, 22 (Colo. App. 1989 , aff ' d. 791 P. 2d 696 (Colo. 1990 ) . The Comprehensive Plan is clearly a policy document. C.R. S . 30-28-106 ( 3) The Charter requires such a document to be adopted by the Board of County Commissioners and the Board did so, after 15 review by the Planning Commission, on three occasions during the last seven years . This interpretation by the staff and Board of Weld County that the Comprehensive Plan, by Charter, was required to be adopted by the Board is entitled to "persuasive" effect by the courts . Mile High Enterprises, Inc . v. Dee, 192 Colo. 326 , 558 P. 2d 568, 573 ( 1977 ) ; Darnell v. City of Englewood, 740 P. 2d 536 , 537 (Colo. App. 1787 ) . The plain language of the Charter and the consistent interpretation by the County staff and elected and appointed officials should lead the court to the conclusion that the Comprehensive Plan was properly enacted. C. The Board of County Commissioners Properly and Appropriately Applied the Comprehensive Plan to the Consideration of Plaintiff ' s Applications . Plaintiffs appear to contend that they have a right to the creation of 12 lots , each less than 35 acres in size, because no rezoning was required prior to making application for a minor subdivision. This violates the basic premise of Colorado law with respect to subdivisions as defined under C.R. S . § 30-28-101 ( 10) and Section 30-28-110(4 ) . Those sections provide that, absent an express exemption from the definition of subdivision or an approval by the Board of County Commissioners, the creation and sale of parcels less than 35 acres in size in unincorporated portions of Counties is illegal . The Plaintiffs, in fact, made application for 16 two minor subdivisions to create the multiple lots and now appear to argue that such a process which they purported to comply with is meaningless . The agricultural zone district under the Zoning Ordinance at Section 31 . 2 . 2, as it existed at the time of the application by the Plaintiff for the site plan for the minor subdivisions, still requires application and approval under Section 4 of the Sub- division Ordinance (minor subdivision) before the lots are considered to be legal . The consideration of a subdivision appli- cation is a discretionary act by the Board of County Commissioners . Meyer v. Buffalo Park Development Company, 607 P. 2d 401, 402 (Colo. App. 1980 ) . This is distinguished from the ministerial process for obtaining a building permit where all one has to do if zoning and subdivision requirements are met is make a technically sufficient application to build the structure . The argument that the appli- cant has a right to a subdivision simply because they were already in compliance with zoning was rejected by the Court in Shoptaugh v. Board of County Commissioners , 37 Colo. App. 39 , 543 P. 2d 524 ( 1975 ) at 527 ; Cited with approval in Coffey v. Maryland-National Capital Park and Planning Commission MD. , 441 A. 2d 1041, 1044 . Specifically, the Shoptaugh court rejected the argument that the use of the land to create five acre subdivisions was a use by right because an application for subdivision was allowed by law and that the Board had to change the zoning or approve the plat. "This 17 argument fails to take into consideration the subdivider must first meet the zoning regulations and then additionally must comply with the state and county subdivision regulations . " Vick v. Board of County Commissioners, 689 P. 2d 699 (Colo. App. 1984 ) appears to be the cornerstone of much of Plaintiffs ' argument . Vick is a questionable proposition of law at this point and specifically inapplicable to this case. Consideration of Vick requires a review of the law with respect to the Subdivision Ordinance and the relationship to master or comprehensive plans in Colorado. See, for example, Conder v. Board of County Commis- sioners of Larimer County, et. al . , District Court, Larimer County, Case # 93-CV-632-5 at pg. 5, decided April 29 , 1994 , attached, which declined to follow Vick, relying upon Beaver Meadows v. Board of County Commissioners , 709 P. 2d 928 (Colo. 1985) . Section 30-28- 102 , C.R. S . , grants counties authorities to provide for the physical development of unincorporated territory within the county in a manner provided for by the statutes . Section 29-20-101, C.R.S . , et seq. , grants counties authority to provide for regu- lating the location of activities and developments which may result in significant changes in population density, provide for phased development of services facilities, regulate the use of land on the base of the impact on the community and surrounding area and otherwise plan for and regulate the use of land so as to provide planned and orderly use of land and protection of the environment. 18 This statute reaffirms that land use authority is a matter of local, not state-wide, concern and within the clear authority of counties . Voss v. Lundvall, 830 P. 2d 1061, 1064 (Colo . 1992 ) ; Board of County Commissioners v. Bowen-Edwards , 830 P. 2d 1045, 1056 (Colo. 1992) . Other relevant powers include C.R.S. § 30-28-133( 5) , which prohibits the granting of any subdivision approvals unless a subdivision has been found to meet all "sound planning and engineering requirements of the county contained in its Subdivision Regulations" , and C.R.S. §S 30-28-106 and 107, which provide for the adoption of a county Comprehensive Master Plan. Weld County implements those powers by means of the Subdivi- sion Ordinance adopted pursuant to Charter and § 30-28-133, C . R. S . , and the Comprehensive Plan adopted in accordance with the Charter and C.R. S . § 30-28-106 . This plan, as adopted by the Planning Commission and made an ordinance by the Board in the case of Weld County, was done in accordance with the general purpose of "guiding and accomplishing a coordinated, adjusted, and harmonious develop- ment of the County . . . " . C .R.S. § 30-28-123 specifically provides that when statutes or local regulations enacted thereunder conflict the statute or regula-tion imposing the highest standard controls and that under these circumstances the highest standard imposed under all the county land use regulations, zoning, subdivision, and master plan 19 are the controlling standards for a subdivision. The Subdivision Ordinance explicitly requires the staff, the Planning Commission, and the Board to make findings regarding compliance with the Comprehensive Plan and find compliance before approving any such minor subdivision. (Subdivision Ordinance Section 4 . 5 . 9 . 1 . ) The provision goes beyond a requirement of considering the Comprehensive Plan as an advisory document and mandates a finding of compliance before approval can be made of a minor subdivision which distinguishes it from Vick at page 700 . The Court of Appeals in Vick summarized the circumstance as follows : "Larimer County by resolution had adopted a land development Master Plan, and it has Zoning and Subdivision Regulations . The Vick subdivision plat satisfied all requirements of the Zoning and Subdivision Resolutions . However, the basic reason the Board did not approve the plat was the plat ' s alleged failure to comply with the Comprehensive or Master Plan for the county. This Plan is referred to in the Subdivision Regulations wherein it is provided that; ' In designing and planning subdivisions , consideration should be given to the Larimer County Master Plan and the Larimer County Zoning Regulations . ' (emphasis added) The actual provision of the Larimer County Plan relied upon by Larimer County was a land use plan for the Town of Estes Park and the surrounding area which was "adopted by the county and functioned as elements of the [county] Comprehensive Plan" . The Comprehensive Plan does not appear to have been a specific element 20 of proof under the Larimer County Subdivision Regulation, but rather a "consideration" for design and planning. This is a critical distinction because the Vick Court relied on the language of Theobald v. Board of County Commissioners , 644 P.2d 942 (Colo. 1982 ) , which stated that the Comprehensive Plan, in that instance, was advisory only. In Beaver Meadows v. Board of County Commis- sioners of the County of Larimer, 709 P . 2d 928, 936 (Colo. 1985) , the court expressly recognized that where the legislative body, here the Board of County Commissioners, has decided to bind itself to the provisions of a Comprehensive Plan rather than treating it as advisory, it has then created a requirement which must be followed, not merely considered. See also Tri-State Generation v. City of Thornton, 647 P. 2d 670, 678 ( 1982 ) ; Conda v. Colorado State Board of Land Commissioners, 782 P . 2d 851 , 853 (Colo . App. 1989 ) aff 'd 809 P. 2d 974 ( 1991) ; C & M Sand and Gravel v. Board of County Commissioners of Boulder, 673 P . 2d 1013, 1018 (Colo. App. 1983) which allow conformity with the "general intent of the Compre- hensive Master Plan . . . " to be considered as an element of approval for a specific development proposal . To the extent Vick is good law, it would only apply where a county has not elected to make compliance with the Comprehensive Plan mandatory. Weld County, using its structural home rule powers , has chosen, consistent with charter, statute, and case law, to make compliance with the Comprehensive Plan mandatory as to minor subdivisions . 21 CONCLUSION The Defendants respectfully request that the Court deny Plaintiffs ' Motion for Summary Judgment; find that the Comprehen- sive Plan is valid and that a finding of compliance with the Comprehensive Plan is required prior to granting minor subdivision approval ; and find that the Board of County Commissioners did not exceed its jurisdiction nor abuse its discretion in denying Plaintiffs minor subdivision applications . BOARD OF COUNTY COMMISSIONERS OF THE COUNTY OF WELD, STATE OF COLORADO, Petitioner BRUCE T. BARKER WELD COUNTY ATTORNEY "lEE �RRISON #8067 Assistant Weld County Attorney 915 Tenth Street P.O. Box 1948 Greeley, CO 80632 ( 303) 356-4000 , Ext. 4391 22 CERTIFICATE OF MAILING The undersigned hereby certifies that a true and correct copy of the foregoing BRIEF IN RESPONSE TO PLAINTIFFS ' MOTION FOR SUMMARY JUDGMENT AND BRIEF PURSUANT TO RULE 106 AND DEFENDANTS ' CROSS-MOTION FOR SUMMARY JUDGMENT ON PLAINTIFFS ' DECLARATORY JUDGMENT CLAIM was placed in the United States mail, postage prepaid, addressed to: John Chilson 6610 Chokecherry Drive Loveland, CO 80537 DATED this a*1 day of -� , 1994 . � C( Qak b94cv203.gjb 23 rikr DISTRICT COURT, COUNTY OF LARIMER, STATE OF COLORADO CASE NUMBER 93 CV 632 - 5 ORDER STEVE CONDER and WENDY SOMMERVOLD, 1\v-c. Plaintiffs , t (etaClE2mGLY1_00H. v. THE BOARD OF COUNTY COMMISSIONERS OF LARIMER COUNTY, Courtlyn Hotchkiss, James Disney and Janet Duvall, County Commissioners , THE LARIMER COUNTY PLANNING DEPARTMENT, Steve Barnett, Department Head, Defendants . This matter is before the Court with regard to plaintiffs' complaint for mandamus under C.R.C.P . Rule 106 (a) (2 ) , judicial review under C.R.C.P . 106 (a) (4 ) , and declaratory judyment. The Court has reviewed all of the briefs, and has reviewed the record filed in this case, including the transcript of a public hearing before the Latimer County Commissioners concerning an application for subdivision approval (Volume III of the record) . The Court has also had the benefit of oral argument. The Court finds , concludes, and orders as follows . BACKGROUND Plaintiffs brought this action for declaratory relief, and for review pursuant to Rule 106 (a) (4 ) , with regard to denial of an application for subdivision approval by the Board of County Commissioners . Plaintiffs also sought relief in the nature of mandamus to require defendants to perform what plaintiffs characterized as a ministerial, nondiscretionary duty; however, plaintiffs have confessed that portion of the Motion to Dismiss and have withdrawn the mandamus claim. Plaintiffs own approximately 560 acres in the southern part of Larimer County, property they acquired for investment purposes . The area in question in zoned FA-1, which allows for single family residences. Plaintiffs obtained a preliminary plat, and in November of 1993 filed their initial subdivision application. A hearing was scheduled before the planning commission, and planning department staff recommended that the application be denied. Plaintiffs withdrew the plat from consideration before the hearing, and thereafter submitted a revised subdivision proposal, revised and amended to address certain problems identified by staff with regard to the initial proposal. This application was considered by the planning commission in July of 1993 , and it recommended denial of the application, as being inconsistent with the land use plan. The matter came before the Board of County Commissioners August 23 , 1993 . See Volume III of the record. The board heard from counsel for the applicants , the applicants , and individuals appearing in support of and in opposition to the application. The issue again was raised that the proposal was inconsistent with the comprehensive land use plan. The Board of County Commissioners voted unanimously to deny the application. The denial was based either in large part, or wholly ( in the opinion of plaintiffs ) upon the view that the application was inconsistent with the comprehensive land use plan for Larimer County. 2 Thereafter, this action for review pursuant to Rule 106 was brought by plaintiffs. DISCUSSION AND CONCLUSIONS REGARDING ISSUES RAISED ON REVIEW Plaintiffs first assert that the action of the board, denying the subdivision application, was contrary to law, and was not supported by the evidence. The standard to be applied by the Court for review pursuant to Rule 106 (a) (4 ) is whether the actions of defendants exceeded their jurisdiction, or amounted to an abuse of discretion (Madis v. Higginson, 164 Colo. 320, 434 P . 2d 705 ( 1967 ) ) . In order for the Court to set aside the decision of an inferior body on review pursuant to Rule 106 , there must be no competent evidence in the record to support such decision (Ford Leasing Development Company v. The Board of County Commissioners , 186 Colo. 418 , 528 P . 2d 237 ( 1974 ) ; Dillon Companies, Inc . v. The City of Boulder, 183 Colo. 117 , 515 P. 2d 627 ( 1973 ) ) . One assertion made by plaintiffs, with regard to the action of defendants exceeding their jurisdiction, which was also asserted, as the Court understands it, in the now withdrawn mandamus claim, is that, since all requirements of the zoning resolution and subdivision regulations were met, plaintiffs were entitled as a matter to law to have the defendant approve their subdivision application. In other words , the granting of approval amounted to a mere ministerial act, required of defendants , if , as plaintiffs assert here, they met all the appropriate requirements, such as would be the case, for example, with regard to issuing a building permit. The Court agrees with defendants that the law in Colorado 3 is otherwise. See Shoptaugh v. Board of County Commissioners, 37 Colo. App. 39 , 543 P . 2d 524 ( 1975 ) ; City of Colorado Springs v. Smartt, 620 P. 2d 1060 (Colo. 1980 ) ; Meyer v. Buffalo Park Development Co. , 607 P . 2d 401 (.Colo. App. 1980 ) . Plaintiffs also assert that defendants abused their discretion, exceeded their jurisdiction, or took an action unsupported by any competent evidence, in that the denial of the application was based entirely upon the assertion that the comprehensive land use plan was incompatible with the application. This they may not do, assert plaintiffs, pursuant to Vick v. County Commissioners, 689 P . 2d 699 (Colo. App. 1984 ) and Theobald v. Board of County Commissioners , 644 P . 2d 942 (Colo. 1982 ) . Pursuant to Vick, plaintiffs argue that the comprehensive land use plan is to be viewed as a guide for future zoning, not as a regulation to be employed with regard to subdivision applications , and using it as such amounts in essence to an illegal rezoning. The Court disagrees with plaintiffs for two reasons . First, the Court does not agree with the assertion of plaintiffs that the only basis for denial was the asserted incompatibility with the comprehensive land use plan. Clearly, plaintiffs are correct in asserting that incompatibility with the plan weighed large in the minds of the commissioners . Such incompatibility was a major consideration, perhaps the main consideration. It is not accurate to say, however, that it was the only consideration. A transcript reveals that other concerns were identified; plaintiffs maintained that all of these concerns were adequately addressed and 4 eliminated, but this is a question of fact which was to be resolved by the commissioners, not by this Court on review, where there is conflicting evidence . For example, the Berthoud water concern was raised, and discussed at some length, although it is correct that the town of Berthoud had withdrawn its previous written opposition. The concern, however, to some extent, apparently remained in the minds of staff and the commissioners . There also were other concerns not directly related to the plan, raised by the commissioners, staff , and others who spoke in opposition to the project. Further, the Court believes that reliance on or reference to the comprehensive land use plan by the defendants did not amount to a violation of law. To the extent that Vick holds to the contrary, the Court believes Vick has been overruled by the Colorado Supreme Court in Beaver Meadows v. Board of County Commissioners , 709 P.2d 928 (Colo. 1985 ) . In that opinion the Colorado Supreme Court discussed at length the various legislative grants of authority resulting in adoption of a comprehensive plan, and the various things which may be considered by a board of county commissioners in passing upon subdivision or PUD applications . A fair and reasonable reading of Beaver Meadows must lead to the conclusion that the Colorado Supreme Court approves consideration of the concerns and principles stated in the comprehensive plan, when passing upon a subdivision application. This is what was done here. The action of defendants being consistent with the holding in Beaver Meadows, the Court determines that such action does not 5 amount to a violation of Colorado law, notwithstanding the prior Vick case. The various concerns raised by the defendants, which led to the denial of the application, were supported by substantial evidence in the record. Clearly, there was other evidence to the contrary. The test on review is not whether the reviewing Court would, faced with the same evidence, have reached the same result, but whether the decision of the Board of County Commissioners was supported by substantial competent evidence. The answer must be in the affirmative in this case. Plaintiffs also assert that the Latimer County Comprehensive Land Use Plan, and the consideration of such plan by defendants in the course of denying their subdivision application, are unconstitutional. They assert that consideration of the plan by defendants amounts to an unconstitutional denial of due process . Based upon Beaver Meadows v. Board of County Commissioners, supra, the Court believes that consideration of the plan was appropriate and does not amount to a denial of due process . It is also asserted that the plan lacks adequate and necessary standards and specificity to meet appropriate constitutional requirements , lacks objective standards , is overbroad, and is vague. Plaintiffs have the burden of establishing this assertion beyond a reasonable doubt (Board of County Commissioners v. Simmons , 177 Colo. 347 , 494 P. 2d 85 ( 1972 ) ) . The comprehensive land use plan uses terms such as harmony, compatibility, need, and so forth, which are within the ordinary understanding of reasonable people, and which have been 6 • • approved on appellate review, in the context of a constitutional challenge, in similar circumstances. See Tri-State Generation, Etc. v. City of Thornton, Colo. 1982, 647 P.2d 670. A person of ordinary intelligence is not required to guess or speculate as to the meaning of these terms . The plan appears to the Court to contain sufficient standards that all parties will be apprised of their respective rights, and a sufficient bench mark exists for measuring administrative action in case of subsequent judicial review (Tri- State Generation, supra) . The Court does not believe that plaintiffs have overcome the presumption of validity and constitutionality with regard to the plan, or the use of the plan in this case (Sundance Hills Homeowners Association v. Board of County Commissioners , 188 Colo. 321, 534 P .2d 1212 ( 1975 ) ) . Plaintiffs next content that the Latimer County Comprehensive Procedural Land Use Resolution was not properly and legally adopted, with appropriate notice being given pursuant to law. The Court ' has reviewed the record in this case, including the supplemental record certified to the Court February 28, 1994 , and is unable to determine, on the state of the record at the time, whether there is a genuine dispute of material fact as to this issue. The Court reserves a ruling on this issue for a period of 30 days ; the Court affords plaintiffs a period of 15 days from the date of this order to file such additional affidavits or other materials that they may wish the Court to consider with regard to this issue; and defendants a further 15 days thereafter to supplement the record by affidavit or otherwise as they deem 7 • appropriate. Thereafter, the Court will rule upon this issue, and may direct that an evidentiary hearing be held if it appears that there is a genuine dispute as to a material fact . IT IS THEREFORE ORDERED that the Court resolves the issues for defendants and against plaintiffs with regard to the complaint for mandamus , judicial review, and declaratory judgment, and denies the various claims for relief brought by plaintiffs, except for the 6th claim for relief, wherein the Court reserves a ruling for additional submissions or possible evidentiary hearing, as stated above. DATED this day of April, 1994 . BY THE COURT: District Court Judge CERTIFICATE OF MAILING This is to certify that on the day of April , 1994 , a true and correct copy of the abo e and foregoing Order was delivered to the attorney of record and parties appearing pro se in the following manner: For counsel in Fort Collins , who have agreed to such procedure: by placing said copy in the attorney ' s pick-up box located in the Latimer County Courthouse, 200 West Oak, Fort Collins , Colorado. For all other counsel, or parties appearing pro se: deposited in the United States Mail with the c rect p to a ixe thereon cc: /1 8 Hello