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Midland Township v. Rapanos

Citations: 199 N.W.2d 548; 41 Mich. App. 75; 1972 Mich. App. LEXIS 1281Docket: Docket 11363

Court: Michigan Court of Appeals; May 25, 1972; Michigan; State Appellate Court

Narrative Opinion Summary

This case involves a defendant who erected billboards on property zoned as Residential 'A', where such structures were prohibited. The defendant applied for a permit to illuminate the billboards, which was denied, prompting the township to seek a mandatory injunction for the removal of the signs due to a violation of the zoning ordinance. The defendant challenged the ordinance, arguing its invalidity and unreasonableness in application to his property. The trial court favored the township, granting the injunction, leading to an appeal by the defendant. On appeal, the court emphasized that zoning ordinances are presumed valid, and the burden of proving them arbitrary and unreasonable falls on the challenger. The court found no protected status for billboards under Michigan law and affirmed the trial court's decision, citing the defendant's failure to demonstrate that the ordinance was unrelated to public health, safety, or welfare. No costs were awarded, and the injunction against the defendant was upheld, reinforcing the authority of local zoning regulations in governing land use.

Legal Issues Addressed

Burden of Proof in Zoning Disputes

Application: The defendant was required to prove the zoning ordinance was arbitrary and unreasonable, which he failed to do.

Reasoning: The court noted that Rapanos bore the burden of proving the ordinance was arbitrary and unreasonable.

Substantial Relationship to Public Welfare

Application: The defendant's failure to show that the ordinance lacked a substantial relationship to public health, safety, or welfare led to the affirmation of the injunction.

Reasoning: Rapanos failed to demonstrate that the ordinance lacked a substantial relationship to public health, safety, or welfare.

Zoning Ordinances and Presumption of Validity

Application: The court upheld the zoning ordinance prohibiting billboards, noting that such ordinances are presumed valid unless proven otherwise.

Reasoning: The court reiterated that zoning ordinances are presumed valid, and the absence of development or complaints about the signs did not suffice to challenge the zoning's validity.