Township of Williamstown v. Sandalwood Ranch LLC
325 Mich. App. 541
Mich. Ct. App.2018Background
- Sandalwood Ranch (defendants) operate a commercial horse-boarding facility with a barn/arena that contains a second‑floor three‑bedroom apartment. The Kolendas are the principal owners/operators.
- Williamstown Township zoning ordinance allows one dwelling per farm (the principal residence) and prohibits living quarters in an arena building.
- Township notified defendants (Dec 2014) that use of the apartment as a second dwelling violated the ordinance; defendants asserted protection under the Michigan Right to Farm Act (RTFA).
- Township sued seeking injunctive relief; trial court held an evidentiary hearing and found the apartment use was not “necessary” to farm operations under MCL 286.472(b).
- The trial court granted summary disposition and a permanent injunction; defendants appealed arguing RTFA protection and asserting estoppel and laches.
- The Court of Appeals affirmed: the apartment’s residential use was not a protected “farm operation” because it was not necessary to commercial horse‑boarding, and defendants failed to support equitable defenses with evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the apartment use is protected by RTFA §286.472(a) ("farm") or §286.472(b) ("farm operation") | Township: the ordinance regulates the use (residential) not the building; RTFA farm definition doesn't immunize non‑agricultural uses inside farm buildings | Defendants: apartment is part of the arena building and thus falls within the §2(a) definition of "farm" | Court: §2(a) protects the building but not every activity inside; proper inquiry is whether the apartment use is a §2(b) "farm operation"; §2(b) applies |
| Whether apartment rental as a second dwelling is "necessary" under RTFA §286.472(b) | Township: "necessary" requires more than convenience; the apartment rental is not necessary to horse‑boarding | Defendants: "necessary" should be read broadly as "useful or proper"; tenant provided nightly checks so functionally necessary | Court: "necessary" not read so broadly here; facts show rental was convenience/flexibility and a source of non‑farm income, not indispensable to commercial farm operations; not protected |
| Whether estoppel or laches bar Township’s enforcement | Township: no evidence defendants relied to their prejudice on township representations or delay | Defendants: township approved original permit/sketches and waited years before enforcement; thus estoppel/laches apply | Court: defendants failed to produce documentary or other evidence supporting estoppel/laches or any prejudice from delay; defenses fail |
| Whether summary disposition and injunction were proper | Township: no genuine factual dispute on necessity and defendants not entitled to RTFA protection | Defendants: disputed factual issues (use, necessity, estoppel) preclude summary disposition | Court: evidence does not create a genuine material factual issue on necessity or on equitable defenses; summary disposition and injunction affirmed |
Key Cases Cited
- Northville Twp v. Coyne, 170 Mich. App. 446 (Mich. Ct. App. 1988) (purpose of RTFA shielding farms/farm operations from nuisance findings)
- Scholma v. Ottawa Co. Rd. Comm., 303 Mich. App. 12 (Mich. Ct. App. 2013) (discussion of RTFA scope and GAAMP conformity)
- Lima Twp v. Bateson, 302 Mich. App. 483 (Mich. Ct. App. 2013) (burden elements for asserting RTFA as affirmative defense)
- Lyons Charter Twp v. Petty, 317 Mich. App. 482 (Mich. Ct. App. 2016) (elements and prejudice requirement for laches)
- Palenkas v. Beaumont Hosp., 432 Mich. 527 (Mich. 1989) (burden‑shifting once party introduces evidence supporting an affirmative defense)
- Blackhawk Dev. Corp. v. Village of Dexter, 473 Mich. 33 (Mich. 2005) (appellate review standard for equitable doctrines)