AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

The case concerns a developer's proposal to construct two-story residences in the Westside-Guadalupe historic district of Santa Fe. The proposal was initially tabled by the Historic Design Review Board to address stylistic and neighborhood concerns. During this time, the City amended its code to allow the Board to impose stricter height limits in historic districts. The Board subsequently denied the proposal under the new amendment, citing the inappropriateness of second-story structures.

Procedural History

• District Court, Santa Fe County: The district court reversed the City's denial of the permits, holding that the retroactive application of the height amendment violated the developer's due process rights.

Parties' Submissions

• City of Santa Fe (Appellant/Cross-Appellee): Argued that the district court erred in finding a due process violation and that the developer had no vested right to the prior zoning rules. The City relied on precedent from Brazos Land, Inc. v. Board of County Commissioners to support its position.
• Developer (Appellee/Cross-Appellant): Contended that the height amendment unlawfully delegated zoning authority to the Board, violated equal protection due to inconsistent application, and constituted an unlawful down-zoning and retroactive application of the law.

Legal Issues

• Was the retroactive application of the height amendment to the developer's proposal a violation of due process?
• Did the height amendment unlawfully delegate zoning authority to the Historic Design Review Board?
• Did the height amendment violate the developer's right to equal protection?
• Did the application of the height amendment constitute an unlawful down-zoning of the developer's property?

Disposition

• The Court of Appeals reversed the district court's decision and upheld the City's denial of the developer's application.

Reasons

Per Pickard J. (Alarid and Bustamante JJ. concurring):

• The Court held that the developer's proposal was not a "pending case" under the New Mexico Constitution, as it had not been approved before the height amendment was enacted. The developer, therefore, had no vested right to the prior zoning rules.
• The Court distinguished the case from State ex rel. Edwards v. City of Clovis, finding that Edwards applied to approved projects, whereas the developer's proposal was unapproved and subject to the new regulations.
• The Court rejected the argument that the height amendment unlawfully delegated zoning authority, citing precedent that allowed historic district boards to enforce design standards within broadly stated guidelines.
• The equal protection claim was dismissed due to a lack of evidence showing discriminatory treatment in the approval of a similar project.
• The Court found no unlawful down-zoning, as the height amendment applied city-wide to all historic districts and was not a piecemeal zoning change targeting the developer's property.
• The Court emphasized that applying new regulations to unapproved applications ensures orderly governance and avoids chaos in land-use planning.