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 Defendant operates a residential care facility that predates zoning restrictions and is thus classified as a legal non-conforming use. The Defendant sought administrative approval to add a modular building for office space, which was challenged by neighboring Plaintiffs as an impermissible expansion of the non-conforming use under the applicable zoning ordinance (paras 1-3).
Procedural History
- Extraterritorial Zoning Commission: Confirmed the Land Use Administrator's approval of the modular building (para 3).
- Santa Fe Extraterritorial Zoning Authority (EZA): Affirmed the Commission's decision, finding the new structure permissible under the zoning ordinance (para 3).
- District Court of Santa Fe County: Reversed the EZA's decision, holding that the zoning ordinance prohibits treating a new building as an extension of a non-conforming use (para 4).
Parties' Submissions
- Plaintiffs (Respondents/Appellees): Argued that the zoning ordinance unambiguously prohibits the addition of new structures as an extension of a non-conforming use and that the EZA's interpretation was erroneous (paras 1, 8).
- Defendant (Petitioner/Appellant): Contended that the ordinance permits the addition of new structures within specified limits and that the EZA's interpretation was reasonable and consistent with prior approvals (paras 1, 8, 11).
Legal Issues
- Whether the zoning ordinance permits the addition of new structures as an extension of a legal non-conforming use.
- Whether the EZA's interpretation of its own ordinance was reasonable and entitled to deference.
Disposition
- The Court of Appeals reversed the District Court's decision and reinstated the EZA's approval of the modular building (para 15).
Reasons
Per Fry J. (Pickard and Sutin JJ. concurring):
The Court found the zoning ordinance ambiguous regarding whether new structures are permissible as extensions of non-conforming uses. Applying principles of statutory interpretation, the Court deferred to the EZA's reasonable interpretation of its own ordinance, which allowed new structures within specified area and intensity limits. The EZA's findings were supported by substantial evidence, including prior approvals of similar expansions. The Court concluded that the ordinance does not prohibit new structures and that the EZA's interpretation was consistent with the ordinance's language and intent. The District Court erred in substituting its interpretation for that of the EZA (paras 8-14).