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 Defendants purchased a 47-acre tract of land in 1987, located in Sandoval County but within the concurrent planning jurisdiction of the County and the Village of Corrales. They began developing a mobile home park on the property in 1988, obtaining a permit for a wastewater treatment system and modifying their plans to include 251 mobile home sites. The County notified the Defendants that their development constituted a "subdivision" under its ordinances, requiring formal approval. In 1989, the Village annexed the property and claimed the development violated its zoning ordinances (paras 2-7).
Procedural History
- District Court of Sandoval County: Held that the Defendants' mobile home park was not subject to the Village's zoning and subdivision ordinances, finding that the Defendants had acquired vested rights to develop the property prior to annexation (paras 6-7).
Parties' Submissions
- Plaintiff-in-Intervention (Village of Corrales): Argued that the Defendants' mobile home park constituted a "subdivision" under both County and Village ordinances, requiring approval. It contended that the Defendants failed to comply with applicable zoning and subdivision regulations and did not establish vested or nonconforming use rights (paras 6, 10-11, 15-19).
- Defendants: Claimed their development was not a "subdivision" under the ordinances, arguing that mobile home parks are akin to apartment complexes. They asserted vested rights to develop the property based on substantial expenditures and the lack of zoning at the time of annexation. They also argued that the Village was estopped from enforcing its ordinances (paras 10, 15, 19).
Legal Issues
- Whether the Defendants' mobile home park constitutes a "subdivision" under the County and Village ordinances.
- Whether the Defendants acquired vested rights or established a nonconforming use exempting them from compliance with the Village's zoning and subdivision ordinances.
- Whether the Village is estopped from enforcing its ordinances against the Defendants.
Disposition
- The judgment of the trial court was reversed, and the case was remanded for further proceedings consistent with the appellate court's opinion (para 20).
Reasons
Per Donnelly J. (Pickard and Bosson JJ. concurring):
The Court held that the Defendants' mobile home park constituted a "subdivision" under both the County and Village ordinances, as the development involved the division of land for lease purposes, aligning with the intent of subdivision laws to ensure harmonious development (paras 13-14). The Court rejected the Defendants' argument that mobile home parks are analogous to apartment complexes, emphasizing that mobile home parks involve land division, unlike apartments, which divide space within a building (para 13).
The Court found that the Defendants failed to establish vested rights because they did not obtain initial approval from the County or Village for their development, a prerequisite for vested rights under New Mexico law (paras 15-16). Additionally, the Defendants did not demonstrate a legal nonconforming use, as they failed to meet the threshold requirement of legality for their development prior to annexation (para 17).
The Court also dismissed the Defendants' estoppel argument, finding no evidence of conduct by the Village that would justify estopping it from enforcing its ordinances. The Village consistently maintained that the Defendants' development required compliance with applicable regulations (para 19).
The Court concluded that the Defendants must seek and obtain approval from the Village for their development, which remains subject to the Village's zoning and subdivision ordinances in effect at the time of application (paras 18, 20).