Evans v. Teton County
Supreme Court of Idaho
73 P.3d 84 (2003)
Teton Springs, L.L.C. sought approval of a Planned Unit Development (PUD) combining a golf course and residential resort on farmland and wetland in Teton County (defendant), along with rezoning. The Teton County Board of County Commissioners (the Board) approved the application. Richard Evans and Matthew Finnegan (plaintiffs), county residents, sued, arguing the approval violated the county's subdivision ordinance's 2-percent cap on incompatible development, the zoning ordinance's ban on residential/commercial/industrial (RCI) PUDs in that zone, and the county's comprehensive plan's density limits. The district court affirmed the Board's decision, and the plaintiffs appealed.
Whether a local zoning board's interpretation and application of its own zoning ordinances is presumed valid when challenged as violating the county's subdivision ordinance, zoning ordinance, and comprehensive plan.