Stoyanoff wanted to build a house in Ladue, Missouri. The house was "unusual in design," but met all of the existing
building and zoning regulations.
Ladue had an "Architectural Board", which used
city ordinances to enforce that all buildings met "minimum standards
of appearance and conformity with surrounding structures." They denied
Stoyanoff's building permit on the grounds that the design was too
outlandish. Stoyanoff sued.
Berkeley was Ladue's building commissioner.
Stoyanoff argued that under the Missouri State constitution, he had been denied due process.
Stoyanoff did not argue that he was being denied due
process under the Federal 14th Amendment.
Stoyanoff wanted to keep this under State law, probably
the US Supreme Court had already held in Berman v. Parker that
aesthetic zoning ordinances were legal. Stoyanoff would have lost if he
went there.
Stoyanoff also argued that, even if aesthetic zoning were
constitutional, the Missouri State legislature had never authorized
cities to make these kind of zoning laws under their Enabling Act.
Stoyanoff also argued that it was not constitutional
(under State law) for the city government to delegate their authority to
a non-elected, private body such as the Architectural Board.
At least not without giving the Board very specific
standards.
The Trial Court issued a writ of mandamus to compel
Berkeley to issue a building permit to Stoyanoff.
The Trial Court found that the city ordinances were
unconstitutional.
Constitution of Missouri, Article 1 Section 10,
that is.
The ordinances were unconstitutional in that they are
vague and provide no standard or uniform rule by which to guide the
architectural board.
Remember writ of mandamus from Marbury v.
Madison? They are legal under some State Constitutions.
Berkeley unsuccessfully argued that having a
"monstrosity of grotesque design" would seriously impair
property values in the neighborhood.
The Missouri Supreme Court reversed.
The Missouri Supreme Court found that the ordinances
provided for clear rules, and that the purpose of the ordinances were to
increase property values. Therefore they were not an improper delegation
of authority.
The Missouri Supreme Court found that that there was
sufficient due process.
They based their reasoning on the fact that the zoning
law wasn't vague, but that's not exactly what Stoyanoff was arguing.
The Missouri Supreme Court also found that since these
aesthetic zoning laws are designed to protect property values, they did
fall under the general enabling law that allowed for zoning.
In this case, the decision rested mainly on the idea of
protecting property values, not on the legitimacy of aesthetic design
requirements in zoning laws.
If bad smells and loud noises can be considered nuisances
and stopped by law, why not unsightly buildings too?
In all cases, there is a subjective standard for what
constitutes a nuisance.
Zoning laws have been held constitutional under the
police power as a form of nuisance control.
Different Courts have ruled different ways on this issue.
Some States have held that zoning laws can be based solely on aesthetic
considerations, other States (like Missouri) require that there be some
other consideration in addition to aesthetics. Pennsylvania
doesn't like aesthetic zoning laws at all.
This is a good case for law students, because it gives a
feeling for how internal State separation of powers issues work. That's
not in a typical 1L curriculum.
