Caseflicks

Court of Appeals of Maryland • 2006

Trip Associates, Inc. v. Mayor of Baltimore

898 A.2d 449 | 392 Md. 563 | 2006 Md. LEXIS 254

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Takeaway

In short, this case holds that Maryland permits a valid nonconforming use to operate more frequently when its essential character and facilities remain the same; more nights of the same adult entertainment are an intensification, not a prohibited expansion.

Background

Anthony Dwight Triplin bought the North Charles Street property in 1983. It had long operated as a nightclub featuring adult entertainment, including exotic dancing. Although adult entertainment was lawful when Triplin acquired the property, Baltimore later enacted Ordinance No. 443, which regulated adult-entertainment businesses and treated qualifying existing businesses as Class III nonconforming uses. Triplin's Club Choices continued to offer partially nude or exotic dancing two nights each week, after hours.

In 2000, a City zoning inspector ordered the club to discontinue adult entertainment unless it secured the required authorization. Triplin appealed to the Board of Municipal and Zoning Appeals. The Board found that the club had a valid nonconforming adult-entertainment use, but approved its continuation only on the condition that adult entertainment occur no more than two nights per week. It also imposed a recording requirement intended to give a neighborhood association standing to enforce the restriction against later owners or operators.

The Circuit Court for Baltimore City affirmed the two-night restriction and additionally required Triplin to obtain all licenses necessary to operate an adult-entertainment business. The Court of Special Appeals agreed that the licensing requirement was erroneous, but upheld the Board's temporal limit. It reasoned that increasing adult entertainment beyond two nights would be an impermissible expansion, rather than a permissible intensification, of a nonconforming use. The Court of Appeals granted certiorari and reversed.

Issues

Issue #1

Whether increasing the number of nights on which Club Choices presents adult entertainment is an impermissible expansion of its Class III nonconforming use or a permissible intensification of that use.

Holding

It is a permissible intensification, not an impermissible expansion. The Board could not restrict the valid nonconforming use to two nights per week merely because that was the frequency shown in the evidence.

Reasoning

A lawful nonconforming use is a vested property right with constitutional protection. Although Maryland zoning law seeks ultimately to eliminate nonconforming uses and strictly construes ordinances against their expansion, a property owner may continue a use that lawfully existed when later zoning legislation rendered it nonconforming.

Baltimore City Code § 13-406 prohibits a Class III nonconforming use from being expanded, unless the Board authorizes the change. But Maryland precedent distinguishes an unlawful extension of a use from a permissible intensification. Intensification occurs when the property is used more frequently for the same essential purpose, without changing the nature and character of the use or substantially enlarging the facilities used.

The Court's prior decisions consistently apply that distinction. Green v. Garrett held that substantially more frequent baseball games at a nonconforming stadium did not extend the use. Nyburg v. Solmson treated an increase in cars stored on a nonconforming garage lot as intensification. Jahnigen v. Staley allowed more rowboats to be rented from a nonconforming marina, and Feldstein v. LaVale Zoning Board treated greater quantities and heights of scrap metal in a junkyard as intensification.

Presenting adult entertainment on more than two nights would increase the frequency of the same adult-entertainment use at Club Choices. It would not change the use's nature or character. Under Feldstein's formulation, using property more frequently for the same or similar purpose is intensification; a change from two to five nights of adult entertainment falls squarely within that rule.

The Court rejected the intermediate appellate court's temporal distinction—that increased activity within existing operating hours is intensification but added days or hours are expansion. Green itself involved a major increase in the frequency and duration of stadium events. Making temporal limits dispositive would undermine Green and make the doctrine of permissible intensification largely meaningless for nightclubs, retail businesses, and other uses with discrete operating hours.

The testimony that adult entertainment had occurred two nights weekly established the existence of the nonconforming use; it did not permanently define its permissible scope. Treating evidentiary proof of historical operations as a ceiling on future operations would effectively discard Maryland's settled intensification doctrine.

The Board's interpretation of the ordinance was entitled to consideration, but judicial deference does not require courts to accept an erroneous legal conclusion. The Court retained responsibility to determine whether the Board correctly interpreted the prohibition on expansion, and concluded that it had not.

Issue #2

Whether the Court of Special Appeals' reliance on decisions from other jurisdictions justified treating a temporal increase as an unlawful expansion under Maryland law.

Holding

No. The out-of-state authorities were distinguishable or rested on policies inconsistent with Maryland's established distinction between intensification and expansion.

Reasoning

Garb-Ko v. Carrollton Township upheld a restriction on expanded grocery-store hours, but it relied on Michigan principles requiring a nonconforming use to remain substantially the same size and essential nature. Those principles did not recognize Maryland's established protection for intensification of an unchanged use.

Time-Low Corp. and Cornell Uniforms involved temporal conditions attached when owners sought permission for substantial physical changes or changes in a nonconforming use. Those cases concerned discretionary Board approval of proposed modifications, not the continuation and more frequent operation of an already valid, unchanged nonconforming use.

The remaining New York authority provided little explanation for its approval of operating-hour limits. It therefore did not supply a persuasive reason to depart from Maryland precedent, particularly Green, Nyburg, Jahnigen, and Feldstein.