artificial night at light

Lindquist v. City of Pasadena

Full Case Name
James and Sandra LINDQUIST, Plaintiffs, v. The CITY OF PASADENA, TEXAS, Defendant
Description

The City's Motor Vehicle Dealers Ordinance set boundaries about how close used-car dealerships can be to residential areas in order to curb any detrimental effects on the surrounding residential communities, including nighttime glare and light pollution. The plaintiffs, owners of a used-car dealership, sued the City for denying their dealership's license, alleging an equal protection claim against the City for treating their dealership differently than others. The Court found there was not sufficient evidence for an equal protection claim and dismissed the case.

Date
09-10-2009
Court
United States District Court for the Southern District of Texas
Jurisdiction
United States
Plaintiffs
Defendants
Incident Location
Pasadena, TX
Disputed Act

The City amended its Motor Vehicle Dealers Ordinance, which required used-car dealers to obtain a license for each location at which they sell cars and set boundaries about how close used-car dealerships can be to residential areas. The Ordinance stated in its preamble that its purpose was to curb any detrimental effects on the surrounding residential communities, including nighttime glare and light pollution. The City denied the plaintiffs a license under the amended Ordinance, the plaintiffs appealed, and the City denied that appeal. The plaintiffs sued the City, alleging that the denial of their license-application appeal violated the Due Process and Equal Protection Clauses of the United States and Texas Constitutions.

Holding
The Court found that the plaintiffs "failed to show that the City exercised unbridled discretion in refusing their appeal" while granting others' appeals and that they "failed to raise a genuine fact issue material to determining whether the City intentionally treated them differently from other similarly situated persons without a rational basis." The Court found that even if the City did not follow all the Ordinance requirements, it followed the purpose of the Ordinance. The Court dismissed the case.
Disposition

Litton International Development Corp. v. City of Simi Valley

Full Case Name
LITTON INTERNATIONAL DEVELOPMENT CORPORATION, Petitioner and Plaintiff, v. CITY OF SIMI VALLEY, the City Council of the City of Simi Valley, Robert O. Huber, Ann Rock, Clyde Evans, Vicky Howard and Greg Stratton, Respondents and Defendants
Description

The Court found that the City of Simi Valley's decision to amend the General Plan designation of the parcel that plaintiff had purchased from "General Commerical with a Hotel/Motel Node" to residential was not arbitrary or unreasonable, and so was constitutional under both state and federal law. The Court dismissed the case.

Date
07-05-1985
Court
United States District Court for the Central District of California
Jurisdiction
United States
Plaintiffs
Defendants
Incident Location
Simi Valley, CA
Disputed Act

After plaintiff company purchased a parcel of land in the City of Simi Valley, plaintiff was denied a permit by the City to develop the property into a hotel. The City had concerns about the effects of noise, lights, and possible night-time disturbance to the residential area near the parcel if the parcel was developed commercially. The City then amended its General Plan so that the parcel could only be used for residential development. Plaintiff company challenged this redesignation as unconstitutional and in violation of state law.

Holding
The Court found that the City of Simi Valley's decision to amend the General Plan designation of the parcel that plaintiff had purchased from "General Commerical with a Hotel/Motel Node" to residential was not arbitrary or unreasonable, and so was constitutional under both state and federal law. The Court dismissed the case.
Disposition

Hall v. City of Ridgeland

Full Case Name
Dr. Charles HALL, Janet H. Clark, Beatrice Langston Berry, Kate Sharp, Belinda Boozer, William Murphy, Carol Murphy, Steve Hanneke, Mary Ellen Martin, Mary S. Godbold, Bobby J. Stokes, Kevin Camp, Gary E. Payne, Maria Rosa Gutierrez, Denise Michelle Wilson, Mary Bishoff, John Austin Evans, Mel Evans, Larry Stowe, Paige Stowe and Kim H. Loper v. The CITY OF RIDGELAND, Mississippi, Madison County Land Company, LLC, Southern Farm Bureau Brokerage Company, Inc., Bailey-Madison, LLC, 200 Renaissance, LLC, 100 Renaissance, LLC and Renaissance at Colony Park, LLC
Description

The Court found that although plaintiff residents had the standing to challenge an ordinance granted by the City of Ridgeland about the construction of a thirteen-story office building near them, the City's decision to allow construction of the building was not arbitrary or capricious and was supported by substantial evidence.

Date
06-10-2010
Court
Mississippi Supreme Court
Jurisdiction
Mississippi
Plaintiffs
Defendants
Incident Location
Ridgeland, Mississippi
Disputed Act

A group of Ridgeland residents challenged the legality of an ordinance issued by the City of Ridgeland to allow developers to construct a thirteen-story office building near them. The residents' concerns about the construction of the commerical development included ingress and egress access issues, depreciation of home values, the height of the building, and after-dark light pollution. The City of Ridgeland argued that the plaintiffs did not have standing to challenge the ordinance.

Holding
The Court held that the plaintiffs had standing to challenge the issuance of the conditional use allowing construction of the building. The Court also held that the City of Ridgeland's ordinance approving the construction of the building near the plaintiff residents was neither arbitrary nor capricious and was supported by substantial evidence.
Disposition