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Why classifying a small-scale land use amendment as a legislative decision is not justified.

Rezoning a 1.3 acre plot from residential to commercial is considered a legislative decision that formulates new policy and is subject to a highly deferential judicial standard of review. (1) In contrast, a rezoning to add up to 600 multi-family residential units in an 885-acre tract is considered a quasi-judicial decision that applies existing policy and is subject to a much less deferential judicial standard of review. (2) These apparently inconsistent results stem from recent Florida Supreme Court decisions that apply a "bright-line" rule classifying all comprehensive plan amendments as legislative decisions and all other zoning changes as quasi-judicial. (3) This article reviews state and local government procedures for various zoning changes, along with a discussion of recent Florida Supreme Court decisions on the classification and standards of review for zoning actions. The analysis demonstrates the inadequate legal justification for the present "bright-line" rule and the resulting inconsistencies in classifying small-scale amendments and rezonings.

Florida Law for Amendments and Rezonings

* Comprehensive Plans are Legislative Actions--A comprehensive plan for land use and zoning establishes a local government's direction for growth and development. (4) As a major policy formulation by a county commission or a city council in its lawmaking role, the plan is a legislative act, which requires a highly deferential standard of judicial review. (5) In contrast, a local government decision that applies an existing legislative policy to an individual case is classified as a quasi-judicial decision. (6) An example is a change of the zoning status of a particular parcel of land from residential to commercial where the future land use map (FLUM) had previously authorized such a use. (7)

* Amending a Comprehensive Plan Entails a Two-stage Process--The state's process for amending a comprehensive plan involves two stages: proposal and adoption. (8) Following a public hearing, the local government submits the proposed amendment for review to the Florida Department of Community Affairs (FDCA) and other regional planning, state, and public agencies. (9) The procedure for the adoption stage depends on whether the FDCA exercises its discretion to review the proposed amendment. (10) If the FDCA reviews the amendment, it issues objections, recommendations, and comments (ORC) report. (11) Following a second public hearing, the local government has 60 days to adopt the amendment as originally drafted, to adopt the amendment with change, or to decide not to adopt the amendment. (12) If the FDCA has not reviewed the amendment and there are no proposed changes or objections from any affected party, the amendment can be adopted directly. (13)

Amendments to a comprehensive plan also reflect land use policies of a local government and have traditionally been considered legislative decisions. (14) The detailed nature of the amendment procedure is consistent with there being considered policy decision affecting many within the locality, as well as agencies and entities outside the local boundaries.

* Legislature and Court Establish Special Considerations for Small-scale Amendments--In some situations, the need has arisen for timely rezoning of a small parcel of land that the local government has failed to include in previous comprehensive plan amendments, but that it considers urgent for the interests of the community, as well as the developer. Both the legislature and the judiciary responded to the need for a more efficient process for these small-scale zoning changes and for a consistent methodology for classification and review of these decisions.

In 1995, the Florida Legislature exempted small-scale amendments from several of the requirements described above. (15) In the proposal phase, the small-scale amendment requires only one hearing compared to two hearings for a large-scale amendment. (16) Although the local government submits all proposed amendments to the FDCA and other agencies, the FDCA has indicated that it does not review small-scale proposals. (17) Furthermore, in the adoption stage, unless challenged, the local government is not required to submit a small-scale amendment to the FDCA as is required for a large-scale amendment. (18)

In 1993, the Florida Supreme Court established the functional analysis test that classified a zoning decision as legislative if it formulated land use policy and as quasi-judicial if it merely applied policy in Board of County Comm'rs v. Snyder, 627 So. 2d 469,474 (Fla. 1993). The court then applied that principle to land use decisions. "Rezoning actions which have an impact on a limited number of persons or property owners, on identifiable parties and interests, where the decision is contingent on a fact or facts ... are quasi-judicial actions...." (19)

Following Snyder, courts were divided on whether small-scale amendments were legislative or quasi-judicial. (20) Fleeman v. City of St. Augustine Beach, 728 So. 2d 1178, 1179-80 (Fla. 5th DCA 1998), held that the request to change the land use of a 0.26-acre plot was an amendment to the comprehensive plan and constituted a legislative act. The court observed that even though it was a small parcel, its proximity to the ocean and to a major thoroughfare suggested important policy concerns. (21)

Grondin v. City of Lake Wales, 5 Fla. L. Weekly Supp. 727 (Fla. 10th Cir. Ct. 1998), determined that the zoning change of a three-acre parcel from single family to commercial qualified as a quasi-judicial decision. According to the court, the proposed land use change was not the broad formulation of policy associated with a legislative decision; rather the city's decision more closely resembled an application of the comprehensive plan as the proposed change was consistent with the plan's policies and text. (22)

* Florida Supreme Court Holds that Small-scale Amendments are Legislative--In 1997, Martin County v. Yusem, 690 So. 2d 1288 (Fla. 1997), established the rule that an amendment to a local government's comprehensive plan, even for a single parcel, is by definition formulation of policy and hence legislative in nature. The court explained that because a land use plan is "like a constitution for all future development," functional analysis is not appropriate for comprehensive plan amendments. (23) Reviewing a proposed amendment requires a county to "engage in policy reformulation" and to promote "orderly development of the County's future growth." (24) The court further justified its conclusion that amendments are legislative decisions by outlining the multi-stage review process required under Florida law. (25) Thus, the court concluded, an amendment requires "strict oversight on the several levels of government," in contrast to a rezoning request, which is evaluated on the local level only. (26)

That the Yusem rule for classifying comprehensive plan amendments as legislative also applied to small-scale amendments was confirmed in Coastal Dev. of N. Fla., Inc. v. City of Jacksonville Beach, 788 So. 2d 209, 210 (Fla. 2001). While recognizing that the procedure for a small-scale amendment is different from that of a large-scale amendment, the court maintained that this procedure still allowed the FDCA to intervene and an affected person to challenge whether an adopted amendment complies with the statute. (27) The court explained that the FLUM, as part of the comprehensive plan, is itself a policy decision. (28) The court distinguished a change in the FLUM (which formulates policy) with a change that is consistent with the FLUM (which applies policy). (29) In addition, no matter what the size of the amendment, the local government must determine whether the reformulation of policies is socially desirable and consider the expected impact on other government services such as traffic and utilities. (30) These considerations differ from those involved in a rezoning. (31)

Inconsistences in Classifying Small-scale Amendments and Rezonings

The bright-line rule has resulted in inconsistencies in classifying land use decisions and inequities in judicial review of these decisions. Specific issues addressed below are the inadequate justifications for designating small-scale amendments as policy and for classifying small-scale amendments differently from small-scale rezonings, and the court's conflicting standards for classifying large-scale rezonings.

* Small-scale Amendments are not Policy Decisions like Large scale Amendments--Coastal and Yusem did not endorse the Snyder functional analysis test, which provided a logical basis for determining whether a decision is legislative or quasi-judicial (i.e., whether it formulates or applies policy). (32) Rather, the Coastal-Yusem court applied a purely mechanical bright-line rule for classifying a comprehensive plan amendment based on a rationale that can be summarized as follows: 1) Because it is an amendment, it is policy; 2) because it is policy, it is legislative; and 3) because it is legislative, it deserves deference (33)

This rationale takes no account of the basic underlying principle for deferring to the legislature based on historical principles of public policy. (34) The policy/principle argument is as follows: 1) The legislature is broad-based, with legislation responding to a diverse constituency; 2) this diverse base gives it authority to make policy and makes it more difficult to provide due process or to address individual concerns; 3) the ultimate recourse of represented citizens is via the ballot box; and 4) thus, legislative decisions deserve deference. (35)

These latter factors are not present for a small-scale amendment. The legislation is not broad-based, but rather is narrowly focused on a single parcel of land. (36) Because it affects only a single parcel, relatively few other landowners are affected and the legislators are unlikely to be voted out of office based on a small-scale amendment. Thus, the decision does not merit the deferential legislative standard of review. (37)

The specific review processes for a small-scale amendment support the claim that it is not policy. For example, the common practice of processing a small-scale amendment in tandem with a rezoning indicates that the levels of community interest and debate anticipated for a small-scale amendment are similar to those for a small-scale rezoning, which is clearly not policy. (38) This process can be contrasted with that of large-scale amendments, which are permitted only twice a year in Florida. (39) For these amendments, municipalities, such as Jacksonville, both anticipate and receive a much wider range of input and comment. (40)

In City of Jacksonville Beach v. Coastal Dev. of North Florida, 730 So. 2d 792, 794 (Fla. 1st DCA 1999), the City of Jacksonville Beach argued that any small-scale amendment would require the city council to consider the policy impact of the amendment, including traffic, utilities, and other services. Yet, the city's brief before the Florida Supreme Court mentioned only that alternate vacant commercial space was available nearby and that the proposed amendment would "violate the plan's goal of encouraging the 'infill' of commercial development." (41) It is hard to see how granting this change for an area less than two acres could significantly affect the city's overall growth plans. Given the significance of this holding, it is disappointing that the court furnished no justification other than repeating that any change in the FLUM is a policy decision. (42)

It is noteworthy that the 1995 amendments to the Florida statutes streamlining the state review for a small-scale amendment were enacted following Snyder (1993), but prior to Yusem (1997). (43) Thus, the legislators were aware of the Snyder functional analysis test under which a small-scale amendment would be subject to quasi-judicial review if it were an application of policy rather than a formulation of policy. (44) The legislature's elimination of a significant portion of the review process of a small-scale amendment is consistent with the recognition that such an amendment does not involve formulation of policy based on the Snyder functional analysis test. (45)

* Adoption Processes are Similar, but Classifications Differ--The practices of several municipalities confirm that the procedures for adopting small-scale amendment are very similar to those for small-scale rezoning. (46) Yet, small-scale amendments are deemed legislative decisions while rezonings are quasi-judicial, resulting in an inherently inconsistent judicial review process. The great similarity in adoption procedures is evidenced by the practice of processing a small-scale amendment and a small-scale rezoning in tandem. In a tandem process, a local government seeking to change the use of a small parcel of land to a use not consistent with the FLUM pairs the small-scale amendment ordinance with a rezoning ordinance for the identical parcel. (47) The board of commissioners first determines whether to approve the amendment to the comprehensive plan. (48) If it approves the amendment, the board determines the suitability of the proposed rezoning. (49) On disapproval, the board never considers the proposed rezoning.

For example, the City of Jacksonville processed a request to allow commercial development on a 1.3-acre plot for a property that had been residential. (50) The new use required a change in the land use designation of the FLUM from low density residential to community general commercial (51) and a change in the zoning district within the new land use designation from residential low density to commercial community general. (52) Following a review and recommendation by staff, the paired ordinances were reviewed successively by the planning commission (the designated land planning agency), the Land Use and Zoning Committee (a subcommittee of the city council), and the city council. (53)

Although the two ordinances were voted on separately, the testimony for and against the ordinances was presented at the same hearings. The first ordinance, which changed the FLUM, was considered a small-scale amendment to the city's comprehensive plan and hence a legislative decision. (54) The second ordinance, proposing a change from one permitted zoning class to another within a land use designation, was a rezoning, not entailing any change to the comprehensive plan and, therefore, classified as quasi-judicial. (55)

Although the substantive processes for enacting a small-scale amendment and a small-scale rezoning are similar, because of their differing classifications, the type of judicial review afforded a challenger also differs. (56) For example, a party opposing the approval of a paired amendment and zoning change would be able to challenge the rezoning portion of the decision under the quasi-judicial process. (57) On the other hand, a person contesting a denial of the amendment would only be able to challenge under the more deferential legislative standard of review. (58)

* Bright-line Rule is Inconsistent with the Functional Analysis Test--The court's bright-line rule in Yusem and Coastal that all amendments are legislative implied that all land use changes not involving a change to the FLUM are quasi-judicial. (59) Because the court did not indicate otherwise, this rule also applies to large-scale rezonings that are consistent with the FLUM. (60) Such a policy seems to be inconsistent with the Snyder functional analysis test, "[a]pplying this criterion, it is evident that comprehensive rezonings affecting a large portion of the public are legislative in nature." (61) Allowing a rezoning of a large tract from, for example, low density residential to commercial could certainly have a major impact on the need for new roads and utilities. Yet, under the bright-line rule, a large-scale rezoning that is not part of a plan amendment would be deemed quasi-judicial and not subject to policy review by the local government or the FDCA. (62)

Because Yusem and Coastal did not overrule Snyder, the Snyder functional analysis test is still valid for determining the classification for a rezoning not involving an amendment. (63) Yusem chose to distinguish rather than to overrule Snyder, explaining "we continue to adhere to our analysis in Snyder with respect to the type of rezonings at issue in that case...." (64) The Coastal court's comment on this distinction, "[h]owever, a proposed zoning change under Snyder must be consistent with the FLUM, thus requiring policy application instead of policy reformulation," (65) also implicitly affirms Snyder.

Under Snyder, a small-scale rezoning affecting only a small number of landowners and a small area is typically designated as quasi-judicial, while a large-scale rezoning, affecting a large area and a large number of individuals is a legislative decision. This analysis, though, is inconsistent with Coastal and Yusem, which imply that all rezonings are quasi-judicial. (66)


The statutes and case law provide an inconsistent framework for classifying land use decisions by local governments. A small-scale amendment, which will often impact only landowners in the immediate vicinity, is not necessarily a true policy decision and thus differs from a large-scale amendment. Florida statutes support this interpretation by excluding small-scale amendments from routine review by FDCA and other procedures required for large-scale amendments. In addition, several municipalities provide essentially the same review procedures for a small-scale amendment as for a rezoning. Yet under Coastal, a small-scale amendment is a legislative decision and a rezoning a quasi-judicial decision.

Because Yusem and Coastal explicitly declined to overrule Snyder regarding land use decisions not involving a plan amendment, Snyder's functional analysis test is still valid for rezonings. This test would conceivably classify the rezoning of a large and strategically placed parcel of land as a formulation of policy, requiring a legislative review process. However, according to the Yusem-Coastal test, only amendments are legislative, with all other rezonings classified as quasi-judicial. Thus, for a large scale rezoning, the Snyder functional analysis test results in a different classification than the Yusem-Coastal bright-line rule.

In conclusion, Yusem and Coastal failed to adequately justify the bright-line rule designating small-scale amendment as legislative decisions. This failure has resulted in the lack of a uniform, rational means for classifying land use decisions.

(1) See JACKSONVILLE, FLA., ORDINANCE 2004-5 (2004) at (hereinafter JACKSONVILLE, FLA., ORDINANCE 2004-5).

(2) See Report of the Planning and Development Department for Application for Rezoning R-2005-117 to Planned Unit Development, February 24, 2005 at asp?F=2005-0117\Reports (hereinafter Application for Rezoning R-2005-117).

(3) The Florida Supreme Court's bright-line rule is that a land use decision is classed as legislative if the action is an amendment to a comprehensive plan and as quasi-judicial if it is not an amendment. See discussion infra.

(4) See Julian C. Juergensmeyer & Thomas E. Roberts, LAND USE PLANNING AND DEVELOPMENT REGULATIDN LAW [section] 2.9 at 27 (2003).

(5) See Michael S. Holman, Zoning Amendment--The Product of Judicial or Quasi-Judicial Action, 33 OHIO ST. L. J. 130, 135 (1972).

(6) A quasi-judicial decision is much less deferential than a legislative decision and will be overturned if there is no competent substantial evidence to support it. In contrast, a court will overturn a legislative decision only if it is arbitrary. See City of Miami Beach v. Ocean & Inland Co., 3 So. 2d 364, 367 (Fla. 1941). In addition, a legislative act is exempt from ex parte restrictions and other procedural due process controls that are normally mandated in a quasi-judicial decision. See Holman, supra note 5 at 141.

(7) The FLUM, a formal part of the comprehensive plan, describes the type of zoning permitted in each parcel of land in the future. The land use categories are the broader zoning classifications (e.g., residential or industrial) while the zoning code represents the subcategories within a land use category (e.g., single family, multi-family, etc.).

(8) FLA. STAT. [section] 163.3184(2004); see also Florida DCA Plan Amendment Process Flow Chart (reflecting revised process pursuant to S.B. 1906, May 31, 2002), available at dcp/Pocedures/PlanAdmb&w85x14.PDF (hereinafter FDCA Flow Chart).

(9) FLA. STAT. [subsection] 163.3167 (2)(b) (2004); 163.3184(3);(5) (2004).

(10) FLA. STAT. [section] 163.3184(5).

(11) FLA. STAT. [section] 163.3184(6)(c).

(12) FLA. STAT. [subsection] 163.3184(15)(b)2; (7).

(13) FLA. STAT. [section] 163.3184(7)(b).

(14) See Juergensmeyer & Roberts, supra note 4, [section] 5.9 at 170.

(15) See Richard Grosso, Florida's Growth Management Act: How Far We Have Come, and How Far We Have Yet to Go, 20 NOVA L. REV. 589, 600 (1996); FLA. STAT. [section] 163.3187(1)(C)1(2004). The act defined a small-scale amendment as one that involves land use of 10 acres or less and does not involve a text change to the goals, policies, or objectives of the comprehensive plan. The definition excludes certain property based on proximity to previously amended tracts, areas of critical state concern and limits the cumulative effect of the amendments.

(16) FLA. STAT. [subsection] 163.3187(1)(C)1; 3.

(17) FLA. STAT. [section] 163.3187(1)(c)2.b.

(18) FDCA Flow Chart, supra note 8 (reflecting revised process pursuant to SB 1906, May 31, 2002). Municipalities and counties are permitted to adopt small-scale amendments immediately upon conclusion of the adoption hearing; FLA. STAT. [section] 166.041(3)(C)1 (2004) (municipalities); FLA. STAT. [section] 125.66(4)(a) (2004) (counties).

(19) Id.

(20) Various commentators have also addressed the issue. Pelham noted that Snyder failed to provide any useful guidance for distinguishing between comprehensive rezoning and small-scale amendments; Thomas G. Pelham, Quasi-Judicial Rezonings: A Commentary on the Snyder Decision and the Consistency Requirement, 9 J. LAND USE & ENVTL. L. 243, 285(1994). He opined that Snyder had consigned local government to years of litigation such as had been experienced in the landmark Oregon case that applied a quasi-judicial standard to rezoning actions; id. (citing Fasano v. Board of County Comm'rs of Washington County, 507 P.2d 23 (Or. 1973)). A former Martin County commissioner observed that applying a quasi-judicial standard to a comprehensive plan amendment shifts responsibility for local land use decisions from elected local officials to elected circuit judges; See Mary Dawson, The Best Laid Plans: The Rise and Fall of Growth Management In Florida, 11 J. LAND USE & ENVTL. L. 325, 327 (1996). She criticized Snyder for removing the discretion of local governments to control land use decisions and to plan for their communities; id, at 373. She also claimed that the application of the quasi-judicial process significantly increased case loads and the cost of litigation, which in turn alienated the public and increased the cost of development; id. at 373-74.

(21) See id.

(22) See id.

(23) Id. at 1293-94.

(24) Id. at 1294.

(20) Id. (citing FLA. STAT. [section] 163.3184(8) (1989)).

(26) Yusem, 690 So. 2d at 1294.

(27) Id. at 207.

(28) Id. at 209.

(29) Id.

(30) Id.

(31) Id.

(32) See Snyder, 627 So. 2d at 474.

(33) See Coastal, 788 So. 2d at 208.

(34) See Carol M. Rose, Planning and Dealing: Piecemeal Land Controls as a Problem of Local Legitimacy, 71 CAL. L. REV. 837,854-856 (1983).

(35) See id. at 854. (citing THE FEDERALIST No. 10, at 56-57, 63-65 (James Madison) (J. Cooke ed. 1961)).

(36) See FLA. STAT. [section] 163.3187(1)(C)1. (limiting a small-scale amendment to an area of 10 or fewer acres).

(37) See Snyder, 627 So. 2d at 474.

(38) The only differences in process between small-scale amendments and small-scale rezonings for the City of Jacksonville are the final review and the submission to FDCA, which is required for the small-scale amendments by statute; see discussion infra.

(39) See FLA. STAT. 3163.3187(1).

(40) Interview with Shannon Scheffer, Office of General Counsel, City of Jacksonville (March 29, 2005).

(41) See Amended Answer Brief of the Respondent at 14, Coastal Dev. of N. Fla., Ina v. City of Jacksonville Beach, 788 So. 2d 204 (Fla. 2001) (No. FL 95,686).

(42) See Coastal, 788 So. 2d at 209.

(43) See 1995 Amendments to Fla. Ch. 9J-5 (FLA. STAT. [subsection] 163.3125-163.3189)(1995).

(44) Snyder, 627 So. 2d at 474.

(45) Yusem, 690 So. 2d at 1295; Coastal, 788 So. 2d at 209.

(46) See JACKSONVILLE, FLA. CODE 3656 (Zoning CODE: Part I, Subpart C: Procedures for Rezoning and Amendments to the Zoning Code); see also JACKSONVILLE BEACH, FLA. CODE [section] 34 (2004) (Development Review Procedures) and NEPTUNE BEACH, FLA. CODE [section] 27-17 (2004) (amending this code); [section] 27-18 (2004) (amending the comprehensive plan).

(47) See id. The small-scale amendment changes the FLUM to the desired land use category while the "in tandem" rezoning changes the zoning code.

(48) See Mark S. Dennison, Zoning Action Not in Accordance with a Comprehensive Plan, 37 AM. JUR. POF 3d 383 [subsection] 1; 2.5. (2004) (citing Standard State Zoning Enabling Act [section] 3 (U.S. Dept. of Commerce rev. ed. 1926)).

(49) Id. (citing Prince v. Payette County Bd. of County Comm'rs, 958 P.2d 583,587 (Idaho 1998)).

(50) The proposed rezoning actually included some additional land to comprise a total of 3.5 acres with alternate zoning districts; these other uses have been excluded from the analysis to avoid confusion.

(51) See JACKSONVILLE, FLA., ORDINANCE 2004-5, supra note 1.

(52) See JACKSONVILLE, FLA., ORDINANCE 2004-6 (2004), available at citycirc.coj. net/coj/COJBillList.asp?Bill=2004-0006 (hereinafter JACKSONVILLE, FLA., ORDINANCE 2004-6).

(53) See id.

(54) JACKSONVILLE, FLA., ORDINANCE 2004-5, supra note 1.

(55) JACKSONVILLE, FLA., ORDINANCE 2004-6, supra note 52.

(56) Because a small-scale amendment is a legislative decision, the court would review it under the highly deferential "fairly debatable" standard of review, whereas the court would review a small-scale rezoning (a quasi-judicial decision) on the basis of whether the evidence was competent and substantial, a much less stringent standard of proof; see Peter W. Salsich, Jr. & Timothy J. Tryniecki, LAND USE REGULATION: A LEGAL ANALYSIS AND PRACTICAL APPLICATION OF LAND USE LAW, at 249-52 (2d ed. 2003).

(57) The second ordinance (regarding the rezoning) would be a quasi-judicial action.

(58) If the council denied the amendment, it would not even vote on the proposed zoning as it would be incompatible with the FLUM.

(59) Id.; Yusem, 690 So. 2d at 1294.

(60) For example, see Application for Rezoning R-2005-117, supra note 2 (application to rezone 885 acres to add 400 to 600 multi-family residential units, while maintaining existing and projected commercial, office, and industrial uses).

(61) Id. In practice, a rezoning expected to have a major impact may well undergo considerable internal review by the designated administrative agency, because the staff or commissioners realize the potential impact and want to minimize criticism and to protect their own positions.

(62) See FLA. STAT. [section] 166.041 (omitting any requirement for a municipality to submit a new ordinance for review to any state agency).

(63) Snyder, 627 So. 2d at 474.

(64) Id.

(65) Coastal, 788 So. 2d at 209.

(66) Id.; Yusem, 690 So. 2d at 1294. Many, if not most, of the municipalities in Florida treat all rezonings not involving an amendment as quasi-judicial, confirming the significance of the inconsistency. See Application for Rezoning R-2005-117, supra note 2.

Bernard R. Appleman received his J.D. in 2005 from Florida Coastal School of Law. The author thanks Professors Stephen Durden and Brian Foley of Florida Coastal School of Law for their guidance and assistance.

The author was the first place award winner of the Environmental & Land Use Law Section 2005 Dean Frank E. Maloney Memorial Writing Contest. This article is submitted on behalf of the section, Robert D. Fingar, chair, and Martha M. Collins, editor.
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Title Annotation:Florida
Author:Appleman, Bernard R.
Publication:Florida Bar Journal
Date:Apr 1, 2006
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