Salotto v. Wickliffe Board of Zoning Appeals, 193 Ohio App. 3d 525

Appellant Vittorio Salotto owns property on East 294th Street in Wickliffe, Ohio, which is a legal nonconforming 75 by 100-foot lot under the R1-50 district.
Wickliffe codified ordinances require minimum 50-foot width and 120-foot depth for R1-50 lots, and limit to one single-family dwelling per lot.
Salotto built a barn/garage adjacent to the residence and converted it into a separate rental residence without obtaining permits.
A notice of violation followed, charging multiple ordinance violations including the single-family-dwelling limit for an R1-50 lot.
Salotto sought variances from the Board of Zoning Appeals: (1) a width variance to allow a second structure on a 39.4-foot-wide new lot and (2) a request to split the property into two lots.
The Board denied the variance request, and Salotto appealed to the trial court under R.C. Chapter 2506; the trial court upheld the Board’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly applied the practical difficulties standard for an area variance	Salotto argues the court misapplied the standard and weighed factors incorrectly	Wickliffe contends the proper area-variance standard was applied and substantial weight given to contrary factors	No reversible error; court did not abuse its discretion

Kisil v. City of Sandusky, 12 Ohio St.3d 30 (Ohio 1984) (establishes practical difficulties standard for area variances)
Duncan v. Middlefield, 23 Ohio St.3d 83 (Ohio 1986) (articulates Duncan factors guiding practical difficulties analysis)