Trustees of Union College v. Members of the Schenectady City Council, 91 N.Y.2d 161, 690 N.E.2d 862, 667 N.Y.S.2d 978 (1997)
A zoning ordinance that completely excludes educational institutions from a residential historic district, without providing a mechanism to balance the educational use against the public interest in historical preservation, is unconstitutional.
Summary
Union College challenged a City of Schenectady zoning ordinance that prohibited educational institutions from applying for special use permits in a Single Family Historic District. The College argued the ordinance was unconstitutional. The New York Court of Appeals held that the ordinance was unconstitutional because it completely excluded educational uses without allowing for a balancing of interests between the educational use and the public interest in historic preservation. The court reasoned that educational institutions have a presumptively beneficial nature and should be evaluated on a case-by-case basis, weighing the public need and benefit against the local impact and effect. The ordinance’s complete exclusion prevented this necessary balancing.
Facts
Union College owned several properties in the General Electric Realty Plot, a historic residential area in Schenectady. In 1978, the City established an A-2 Single Family Historic District, which initially allowed educational, religious, and philanthropic institutions to apply for special use permits. In 1984, the City amended its zoning provisions, restricting special permit uses within the Historic District to public utility facilities only. This effectively foreclosed educational uses. Union College proposed an amendment to allow educational uses as a special permit, but this was rejected. The College then filed a declaratory judgment action arguing the zoning code was facially unconstitutional.
Procedural History
Union College filed a declaratory judgment action against the City of Schenectady, its Mayor, and the Schenectady City Council, seeking a declaration that City Code § 264-8 was unconstitutional. Supreme Court granted the College’s motion for summary judgment. The Appellate Division unanimously affirmed. The City appealed to the New York Court of Appeals.
Issue(s)
- Whether a municipality can constitutionally enact a zoning ordinance that completely excludes educational institutions from applying for special use permits within a residential historic district.
Holding
- No, because the ordinance improperly eliminates any opportunity for balancing individual educational uses against the public’s historical preservation interests, serving no end that is substantially related to the promotion of the public health, safety, morals, or general welfare.
Court’s Reasoning
The Court of Appeals acknowledged the presumption of constitutionality afforded to zoning ordinances but emphasized that such ordinances must substantially relate to promoting public health, safety, morals, or general welfare. While municipalities can enact land-use restrictions to preserve the character and aesthetic features of a city, this interest cannot automatically override competing educational interests. Educational institutions have long enjoyed special treatment regarding zoning ordinances due to their inherently beneficial nature. Citing Cornell Univ. v. Bagnardi, the Court reiterated the general rule that “the total exclusion of [educational] institutions from a residential district serves no end that is reasonably related to the morals, health, welfare and safety of the community.”
The Court emphasized the necessity of evaluating proposed educational uses on a case-by-case basis, balancing them against other legitimate interests, including historic preservation. A special permit process provides zoning boards with the opportunity to weigh the proposed use against neighboring land uses and impose conditions to mitigate adverse effects. The Court found that the Schenectady ordinance’s complete exclusion of educational uses prevented this balancing, effectively declaring that historical preservation interests always outweigh educational interests, which the court deemed was unsupported. The court emphasized that a variance or amendment process does not provide the appropriate forum to weigh the benefits of the particular educational use against the public interest in historical preservation.
The Court concluded that because the City Code failed to provide a means to balance Union College’s proposed educational uses against the public’s interest in historical preservation, it served no end substantially related to the promotion of public health, safety, morals, or general welfare, and was therefore unconstitutional. As the Court stated, the special permit application process “affords zoning boards an opportunity to weigh the proposed use in relation to neighboring land uses and to cushion any adverse effects by the imposition of conditions designed to mitigate them.”