Bonnie Briar Syndicate, Inc. v. Town of Mamaroneck, 94 N.Y.2d 440 (2000)
A zoning regulation constitutes a taking if it does not substantially advance legitimate state interests, and the appropriate standard for determining whether a zoning regulation substantially advances legitimate state interests (when no exaction is involved) is whether the action bears a reasonable relationship to achieving a legitimate objective.
Summary
Bonnie Briar Syndicate sued the Town of Mamaroneck, alleging that a zoning change from residential to recreational use constituted a regulatory taking. The Town rezoned Bonnie Briar’s golf course property to preserve open space, recreational opportunities, and mitigate flooding. Bonnie Briar argued the rezoning didn’t substantially advance these interests, as less restrictive options existed. The court held that the “essential nexus” standard from exaction cases like *Nollan* and *Dolan* doesn’t apply to general zoning regulations. The appropriate standard is whether the regulation bears a reasonable relationship to legitimate objectives. Because the rezoning bore a reasonable relation to legitimate objectives, no taking occurred.
Facts
Bonnie Briar owned a 150-acre property leased as a private golf course since 1921. In 1994, the Town of Mamaroneck rezoned the property from residential to recreational use. The Town had been studying diminishing open spaces since the 1960s, with multiple plans recommending the golf course remain as such. A study highlighted the land’s role in flood control as part of the Sheldrake River floodplain. Bonnie Briar submitted a plan for 71 residential lots before the rezoning.
Procedural History
Bonnie Briar sued, claiming an unconstitutional taking. The Supreme Court initially dismissed the cause of action alleging an insufficiently close relationship between the Town’s goals and zoning ordinance, which the Appellate Division affirmed. The Supreme Court then denied summary judgment for the remaining causes of action concerning an alleged economic taking, but the Appellate Division reversed, granting summary judgment to the Town and declaring the law constitutional. The New York Court of Appeals then heard the case.
Issue(s)
Whether the change in zoning of plaintiff’s property from residential to recreational use, constituted a regulatory taking under the Fifth and Fourteenth Amendments to the United States Constitution because the zoning regulation did not substantially advance legitimate state interests.
Holding
No, because the zoning regulation bears a reasonable relationship to the legitimate objectives of preserving open space, providing recreational opportunities, and mitigating flooding.
Court’s Reasoning
The court applied the *Agins* standard, which asks whether the zoning law substantially advances legitimate state interests and whether it denies an owner economically viable use of their land. Bonnie Briar only pursued the first prong. Bonnie Briar argued that the “close causal nexus” standard from *Seawall* and *Manocherian* applied, requiring a tight fit between the Town’s objectives and the law. The court rejected this, clarifying that the heightened scrutiny of *Nollan* and *Dolan* (essential nexus and rough proportionality) applies only to exaction cases, not general zoning regulations.
The court cited *City of Monterey v. Del Monte Dunes* as reaffirming that the *Agins* standard applies to regulatory takings that do not involve an exaction. In *Del Monte Dunes*, the Supreme Court held that where the landowner’s challenge is based on denial of development, the rough-proportionality test of *Dolan* is inapposite. The court reasoned that because the *Dolan* test does not apply, the ‘essential nexus’ test from *Nollan* also does not apply because the Supreme Court limited its application to cases involving exactions.
“[T]he regulatory actions of the city or any agency substantially advance a legitimate public purpose if the action bears a reasonable relationship to that objective.”
The court concluded that because the rezoning bore a reasonable relation to the Town’s legitimate objectives, no taking occurred. The fact that less restrictive options existed was irrelevant, as long as the chosen method substantially advances the public interest. The court deferred to the zoning board’s judgment and emphasized that it’s not the court’s role to determine if a regulation is more stringent than necessary. The court emphasized that the zoning districts were shifted in response to years of study and documentation regarding recurrent flooding problems and concerns.