Law School Case Brief
Oneida Farms Dev., Inc. v. Town of Huntsville, - No. E2014-02179-COA-R3-CV, 2015 Tenn. App. LEXIS 913 (Ct. App. Nov. 16, 2015)
Pursuant to Tenn. Code Ann. § 6-58-111(a) (2015), a property owner is required to prove that: (1) an annexation ordinance is unreasonable for the overall well-being of the community involved; or (2) the health, safety, and welfare of the citizens and property owners of the municipality and territory will not be materially retarded in the absence of such annexation.
This case involves a quo warranto action challenging the validity and reasonableness of an annexation ordinance. On August 17, 2011, the Town of Huntsville ("the Town") initiated annexation proceedings involving certain properties located within the Town's approved urban growth boundary. One such affected property, nominated Parcel 10, is owned by the plaintiff, Oneida Farms Development, Inc. ("OFDI"). OFDI filed a Complaint for Declaratory Action, thereby initiating the instant action. OFDI sought a temporary restraining order preventing the second reading and adoption of the annexation ordinance. The trial court denied OFDI's request for injunctive relief. The Town adopted an ordinance annexing the property, as well as a Resolution approving the proposed plan of services. The Town filed a Motion for Summary Judgment in the instant action, which was denied by the trial court. The Town thereafter sought an interlocutory appeal regarding the ruling pursuant to Tennessee Rule of Appellate Procedure 9. Although the trial court granted an interlocutory appeal, this Court denied that request. Based on the evidence presented, the trial court concluded that OFDI had failed to prove that (1) the annexation ordinance was unreasonable for the overall well-being of the community, or (2) the health, safety, and welfare of the citizens and property owners of the municipality would not be materially retarded in the absence of such annexation. The court therefore entered a judgment dismissing OFDI's complaint. OFDI timely appealed.
Did the trial court err in determining that OFDI failed to prove that the annexation ordinance was unreasonable?
The trial court properly dismissed a property owner's quo warranto action because, pursuant to Tenn. Code Ann. § 6-58-111 (2015), the owner failed to prove that an annexation ordinance was unreasonable where protection of a lake reservoir was necessary for the public health, safety, and welfare of the town's citizens, the owner's property surrounded the reservoir, the property fell within the town's urban growth boundary, the town had committed to provide services to the annexed property, including sewer, garbage collection, street maintenance, inspections, and a zoning plan, and the owner did not question the town's intent to provide the listed services; -The owner properly asserted a quo warranto challenge to the ordinance because the complaint referenced Tenn. Code Ann. § 6-51-103(2015) and the action was filed prior to the ordinance's operative date.
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