Town of Lysander v. Hafner, 96 N.Y.2d 558 (2001)
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Local zoning ordinances that unreasonably restrict farm operations within agricultural districts are superseded by New York Agriculture and Markets Law § 305-a (1)(a) unless the restriction is necessary to protect public health or safety.
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Summary
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This case addresses whether a town zoning ordinance imposing minimum size requirements for single-family dwellings unreasonably restricts farm operations when applied to mobile homes used to house migrant farm workers. The Court of Appeals held that the ordinance was superseded by Agriculture and Markets Law § 305-a (1)(a) because it unreasonably restricted farm operations and the town failed to demonstrate a threat to public health or safety. The Court emphasized that “on-farm buildings” can include residential buildings necessary for farm operations, and deferred to the Commissioner of Agriculture and Markets’ interpretation of the statute.
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Facts
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Defendants owned a commercial farm in an agricultural district. They attempted to install several single-wide mobile homes to house migrant workers. A Town zoning ordinance required all one-story single-family dwellings to have a minimum living area of 1,100 square feet. The mobile homes did not meet this requirement. The Town initially granted a temporary permit for two mobile homes but later refused to extend the permit or approve applications for additional mobile homes, citing the zoning ordinance.
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Procedural History
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The Town commenced an action for an injunction to prevent the defendants from using the mobile homes without permits and to require their removal. The defendants asserted an affirmative defense that the zoning ordinance unreasonably restricted farm operations under Agriculture and Markets Law § 305-a (1)(a). They also counterclaimed, seeking an order directing the Town to issue the necessary permits. Supreme Court denied the defendant’s motion for summary judgment and granted summary judgment to the Town, issuing a permanent injunction. The Appellate Division affirmed. The Court of Appeals granted leave to appeal.
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Issue(s)
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Whether a local zoning ordinance imposing minimum size requirements for single-family dwellings is superseded by Agriculture and Markets Law § 305-a (1)(a) when applied to mobile homes used to house migrant farm workers on a commercial farm within an agricultural district.
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Holding
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Yes, because the zoning ordinance unreasonably restricted farm operations, and the Town failed to demonstrate that the restriction was necessary to protect public health or safety.
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Court’s Reasoning
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The Court reasoned that Agriculture and Markets Law § 305-a (1)(a) mandates that local governments exercise their land use powers in a manner consistent with the policy objectives of Article 25-AA, which aims to protect and encourage the development of agricultural lands. The Court noted that the Commissioner of Agriculture and Markets concluded that mobile homes used for farmworker residences are protected “on-farm buildings”. While the legislature removed the specific reference to “farm residential buildings” from the definition of “farm operation” in 1997, the court determined this amendment was intended to strengthen, not limit, protections against unreasonably restrictive local laws. The court stated that the statute applies to all buildings located