Snyder House Rules? The New Deference in the Review of Quasi-Judicial Decisions

The Florida Supreme Court made a decision in a case called Board of County Commissioners of Brevard v. Snyder. The decision said that when local governments consider changing zoning laws for land, they have to have good evidence to support their decision. This makes it harder for the government to approve zoning changes. Developers and landowners were happy with this decision, but local governments were worried it would make their jobs harder. The Snyder decision has been hard for courts to apply for the past seven years. They have to decide if zoning decisions are supported by enough evidence, but they also can’t just make their own decision instead of the local zoning boards. A recent case called Florida Power & Light Company v. City of Dania showed that both the circuit court and the district court made mistakes in their reviews under Snyder. The problem comes from the fact that Snyder doesn’t require local governments to include written explanations for their decisions, so it’s hard for courts to know why the zoning board made their decision. This makes it difficult for the courts to review the evidence and make a fair decision. Before Snyder, Florida courts agreed that written findings were necessary to support decisions about zoning changes. These findings helped the reviewing court understand the reasons behind the decision and prevented them from re-evaluating the evidence. They also helped to keep zoning decisions objective and rational. However, in the Snyder case, the Florida Supreme Court decided that written findings are no longer required to support rezoning decisions, which has led to a significant change in how these decisions are reviewed by the courts. Under the Snyder approach, when a local zoning board denies a request to rezone a property, the circuit court must review the entire record to find any evidence that supports the denial, even if it’s not the primary reason given. This means the court could consider a lot of evidence, including things like environmental impacts. On the other hand, the Irvine approach only requires the circuit court to review evidence that directly supports the reasons given for the denial, like if there’s evidence of traffic impacts. So, Snyder requires a much broader review of the evidence than previous methods. If a local zoning board makes a decision to change zoning laws but doesn’t explain why, it makes it difficult for a court to review the decision. This can lead to unfair outcomes for property owners. The Florida Supreme Court has said that these decisions should be reviewed closely, but without written explanations from the zoning board, it’s hard to do that. This can give the zoning board too much power and make it hard for property owners to challenge their decisions. This can also lead to confusion and make it less likely for the zoning board to give written explanations for their decisions in the future. T.R. Hainline, Jr., and Steven Diebenow are lawyers who specialize in land use and zoning law in Jacksonville. They have both been practicing law for a long time and received their law degrees from respected universities. This column is submitted on behalf of a section that focuses on environmental and land use law.

Source: https://www.floridabar.org/the-florida-bar-journal/snyder-house-rules-the-new-deference-in-the-review-of-quasi-judicial-decisions/