Narrative Opinion Summary
In this case, Wayne Goodwyn appealed against the granting of a special exception permit by the Metropolitan Board of Zoning Appeals to Ed Clay for hosting historic home events at East Ivy Mansion in Nashville. The permit allowed events with conditions, including a maximum of 250 guests and a term of 26 months. Goodwyn, a neighboring property owner, argued that the permit was inconsistent with Metro Code 17.16.160(B), which requires such events to occur in historically significant structures. Following public hearings and a favorable decision from the Board, Goodwyn petitioned for a writ of certiorari, claiming the Board's decision was arbitrary and capricious. The Davidson County Circuit Court upheld the permit, and the Court of Appeals affirmed this decision, finding that the Board acted within its jurisdiction and based on material evidence. Mr. Clay's motion to intervene was granted, and the inclusion of the brick wall within the event space was deemed part of the historically significant structure, as supported by testimony from the Historic Zoning Commission. The appeal was denied, with costs assessed against Goodwyn, and the case was remanded for further proceedings as necessary.
Legal Issues Addressed
Collateral Estoppel in Administrative Decisionssubscribe to see similar legal issues
Application: Mr. Clay's argument regarding collateral estoppel was deemed unnecessary to address due to the affirmation of the Board's decision.
Reasoning: The court also stated that Mr. Clay's argument regarding collateral estoppel is unnecessary to address due to this conclusion.
Inclusion of Contiguous Structures in Historical Designationsubscribe to see similar legal issues
Application: The brick wall surrounding the property was deemed part of the historically significant structure, allowing its use for the events.
Reasoning: Testimony from a Historic Zoning Commission official indicated that the wall could be considered part of the dwelling, as it is attached to the structure.
Jurisdictional Impact of Issuing a Writ of Certiorarisubscribe to see similar legal issues
Application: The trial court's consideration of Board proceedings after the writ issuance was not erroneous as the March 2016 proceedings reached the same conclusion as prior actions.
Reasoning: Mr. Goodwyn argues that the trial court improperly relied on the Board’s March 2016 proceedings, which occurred after the writ of certiorari was issued.
Review of Local Board Decisions via Common Law Writ of Certiorarisubscribe to see similar legal issues
Application: The court's review is limited to determining whether the Board acted within its jurisdiction and had material evidence supporting its decision.
Reasoning: The common law writ of certiorari serves as the means for reviewing local board decisions, with limited scope focused on jurisdiction and whether the board acted without support from material evidence.
Special Exception Permits under Metro Code 17.16.160(B)subscribe to see similar legal issues
Application: The Board was authorized to grant a special exception permit for historic home events, including the use of the area within the property's brick wall.
Reasoning: The Board held the authority to issue a permit for events at a historically significant structure, as determined by the historic zoning commission.