Generation Realty, LLC v. Catanzaro, 2011 R.I. LEXIS 64

Rhode Island Supreme Court interprets G.L.1956 § 45-24-53 regarding notice/hearing for zoning amendments.
Ordinance 99-127Z in 1999 overhauled zoning to conform with a 1998 comprehensive plan, affecting ~50% of town land.
Capital City and Generation Realty claimed the rezoning to open space was a specific change requiring individual notice.
Trial court granted summary judgment favoring plaintiffs, finding specific-change notice required.
Court holds the 1999 amendments were general under § 45-24-53 and public notice sufficed; reversal/remand ordered.
Intervenor had argued extensive changes nonetheless required only public notice, consistent with the statute’s general-amendment framework.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 1999 amendments were general or specific under § 45-24-53	Generation Realty, Capital City): amendments were specific; individual notice required	North Providence): amendments were general; public notice sufficient	General amendment; only public notice required

Quigley v. Town of Glocester, 520 A.2d 975 (R.I. 1987) (predecessor notice rule; specific map changes require notice)
Murphy v. Zoning Bd. of Review of South Kingstown, 959 A.2d 535 (R.I. 2008) (statutory interpretation and notice principles)
Ryan v. City of Providence, 11 A.3d 68 (R.I. 2011) (statutory construction; give effect to legislative intent)
D'Amico v. Johnston Partners, 866 A.2d 1222 (R.I. 2005) (interpretation of zoning statutes; context matters)
Sorenson v. Colibri Corp., 650 A.2d 125 (R.I. 1994) (statutory construction principles; whole-act analysis)
Kulawas v. Rhode Island Hospital, 994 A.2d 649 (R.I. 2010) (considers statutory framework and purposive interpretation)