Siena Corporation v. Mayor and City Council of Rock
873 F.3d 456
| 4th Cir. | 2017Background
- Siena planned an ezStorage self-storage facility adjacent to Maryvale Elementary School in Rockville, within a zone allowing such use at the time.
- Residents opposed due to traffic, safety, crime, and environmental concerns, prompting a 250-foot exclusion near schools.
- Rockville enacted a zoning text amendment conditioning/prohibiting self-storage near schools across several zones.
- Siena obtained conditional site plan approval but never satisfied the plan’s nineteen discretionary conditions or applied for a building permit.
- Council adopted the amendment in February 2015 after planning commission review and public hearings; Siena sought Maryland state review but was unsuccessful.
- Siena sued in federal court under 42 U.S.C. § 1983 alleging substantive due process and equal protection violations; district court dismissed or granted summary judgment for the Council.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Siena had a cognizable property interest in building the facility | Siena had a vested right to obtain a building permit under Maryland Rockville rules | No vested right without permit application and full compliance with discretionary site-plan conditions | No cognizable property interest; no vested right; discretionary process defeats entitlement |
| Whether the amendment violates substantive due process | Amendment targeted Siena and deprived its property interest without proper process | Amendment serves a legitimate public health and safety interest; not conscience-shocking | No substantive due process violation; action within police power and rational basis |
| Whether the amendment violates equal protection | Treatment of Siena was discriminatory or arbitrary | Amendment applied generally to all similar zones; not a class-of-one targeting | No equal protection violation; rational relationship to legitimate state interest |
| Whether the district court properly resolved the case on summary judgment | Court should examine harms/benefits balance in land-use decisions | Federal courts should not replace local zoning judgments with empirical inquiries | Affirmed dismissal/summary judgment; deference to local legislative process |
Key Cases Cited
- Village of Euclid v. Ambler Realty Co., 272 U.S. 365 (1926) (land-use regulation within police powers; rational basis permissible)
- Ry. Express Agency v. New York, 336 U.S. 106 (1949) (no requirement to eradicate all evils of same genus)
- Olech v. Willowbrook, 528 U.S. 562 (2000) (class-of-one equal protection standard requires arbitrary treatment absent rational basis)
- A Helping Hand, LLC v. Baltimore County, 515 F.3d 356 (4th Cir. 2008) (vested rights/right to permit require explicit state action and compliance)
- Powell v. Calvert County, 368 Md. 400 (Md. 2002) (vesting rights require permits and compliance with procedures)
- Gardner v. City of Baltimore, 969 F.2d 63 (4th Cir. 1992) (land-use discretion; preventing automatic entitlement to permits)
- Sylvia Dev. Corp. v. Calvert County, 48 F.3d 810 (4th Cir. 1995) (zoning decisions grounded in legitimate public interests)
- Rockville Fuel & Feed Co. v. Gaithersburg, 266 Md. 117 (Md. 1972) (state/local zoning decisions; discretion in planning)