Family of Woodstock, Inc. v. Auerbach
Opinion of the Court
In order to obtain its use variance, petitioner was required to show unnecessary hardship by demonstrating (1) that the property cannot provide a reasonable return as it is currently zoned, (2) that the hardship results from the unique characteristics of the parcel, (3) that the proposed use will not alter the character of the neighborhood, and (4) that the alleged hardship has not been self-created (Village Law § 7-712-b [2] [b]; see, Matter of Courtney v City of Albany Bd. of Zoning Appeals, 177 AD2d 820). Here, although the Board agreed that petitioner established the first and third of these criteria, it nevertheless concluded that petitioner failed to demonstrate the uniqueness of its hardship and that this hardship was not self-created. Upon review of the record, we agree with Supreme Court that the Board’s determination lacked a rational basis.
With respect to the subject of self-created hardship, there was uncontested proof presented that petitioner had no plans to expand upon the existing building until such condition was imposed upon it by the State. Therefore, since petitioner did not knowingly acquire the property for a prohibited use, we agree with Supreme Court that the Board acted arbitrarily and capriciously in determining that the hardship was self-imposed (see, Matter of Eung Lim-Kin v Zoning Bd. of Appeals, 185 AD2d 346, 347-348).
Here, the undisputed proof shows that petitioner would receive a zero return on investment if the property was used for commercial purposes and only a 3% return if utilized as residential rental property, well below the reasonable expected return of 12% to 15% before taxes. In light of this evidence, we conclude that the denial of the variance cannot be sustained solely on the failure to establish "unique circumstances”. Thus, we agree with Supreme Court that the Board’s determination lacked a rational basis.
Cardona, P. J., Mercure, Crew III and Casey, JJ., concur. Ordered that the judgment is affirmed, with costs.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.