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Corona Properties of Florida, Inc. v. Monroe County

Citations: 485 So. 2d 1314; 11 Fla. L. Weekly 628; 1986 Fla. App. LEXIS 6761Docket: No. 85-1786

Court: District Court of Appeal of Florida; March 10, 1986; Florida; State Appellate Court

Narrative Opinion Summary

In this case, Corona Properties of Florida, Inc. challenged the revocation of a building permit issued by Monroe County. The dispute arose over a parcel in Key Largo, initially zoned to allow 58 dwelling units, but re-zoned in 1979 to permit only 24 units. The controversy centered on a vested rights letter issued by the Monroe County Zoning Official, which erroneously assured that a 40-unit building could be constructed despite the zoning change. Relying on this assurance, Corona Properties acquired the property and incurred substantial expenses. The County later revoked the permit, declaring it void ab initio, as the zoning official lacked the authority to issue the vested rights letter. The court upheld this decision, emphasizing that the zoning official's role did not include exempting projects from compliance with zoning laws. Additionally, the court rejected Corona Properties' arguments of equitable estoppel and laches, noting that government entities cannot be estopped from enforcing zoning regulations based on an improperly issued permit. The trial court's judgment was affirmed, maintaining the permit's invalidity and underscoring the limits of zoning officials' authority and the doctrine of equitable estoppel against governmental bodies.

Legal Issues Addressed

Application of the Doctrine of Laches

Application: The doctrine of laches cannot be applied offensively by Corona Properties to prevent the revocation of the building permit.

Reasoning: However, it cannot be applied in this instance as Corona Properties seeks to use it offensively.

Authority of Zoning Officials

Application: The Monroe County Zoning Official did not have the authority to issue a vested rights letter exempting projects from compliance with zoning laws.

Reasoning: It does not empower the official to exempt projects from compliance with zoning laws.

Equitable Estoppel Against Government Entities

Application: Monroe County cannot be equitably estopped from revoking the permit, as allowing estoppel would undermine the enforcement of zoning laws by public officials.

Reasoning: Generally, a governmental body cannot be estopped from enforcing ordinances due to an improperly issued permit.

Vested Rights in Zoning

Application: The vested rights letter and the associated 1983 permit were deemed void ab initio, as the zoning official lacked the authority to determine vested rights.

Reasoning: Consequently, neither section grants the zoning official the authority to determine vested rights, rendering the vested rights letter and the associated 1983 permit void ab initio.