Appeals Court Nixes Crowded School District's Suit Over New Home Construction
The court found a school district's legal options are strictly limited when it comes to opposing new housing construction based on predicted impact on enrollment.
July 23, 2020 at 03:50 PM
3 minute read
Classroom crowding that would be exacerbated by new home construction does not give a school district standing to oppose approval of a land use application, the Appellate Division ruled in a published opinion Wednesday.
The appeals court affirmed dismissal of a suit brought by the Edison Board of Education against Edison's Zoning Board of Adjustment and a developer. The school board wanted to overturn approval of an eight-unit housing complex.
While standing to oppose land use decisions is accorded liberally, a school district's claim of harm from a potential influx of students does not give it standing to oppose a land use application, the appeals court said. However, the Board of Education would likely have standing to challenge approval of new housing near one of its schools if it claimed the development would interfere with the board's right to use or enjoy its property, the appeals court said.
The decision illustrates that a school district's legal options are strictly limited when it comes to opposing new housing construction based on the predicted impact on enrollment.
"The BOE's generalized claim of harm caused by the possibility of students being added to an already overcrowded school district is insufficient to make the BOE an 'interested party,' entitled to litigate its claim under the MLUL," Judge Carmen Messano wrote, joined by Judges Mitchel Ostrer and Ronald Susswein.
The appeals court said it was ruling for substantially the same reasons cited by Judge James Hurley of Middlesex County Superior Court, who dismissed the suit in August 2019. Hurley's ruling noted that the board of education had no interest in the site of the development or adjacent property that would be adversely affected by the development, and that it did not allege that the approval of the housing development had created a likelihood of harm to the board, as a body.
The appeals court also affirmed Hurley's dismissal of a claim that the approval of the housing project was invalid because it was not listed on the zoning board's printed agenda.
The school district filed its suit in April 2019. The suit was seen by land use lawyers as having long odds for success.
Edison attorney Bhavini Tara Shah, representing the zoning board, said the ruling is important because it represents the first case law to clarify that opposition to a land use application based on a claim "that a school will be impacted broadly is not a basis for denial. It can't be such a generalized comment," she said.
Peter Yarem and Rachel Elizabeth Simon of Scarinci Hollenbeck in Lyndhurst, who represented the school district, did not respond to requests for comment.
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