Brief Fact Summary. The Issaquah Development Commission (the Commission) of the City of Issaquah (Appellee) had the authority to approve or deny land use certifications. The Appellants, Anderson and others (Appellants) submitted architectural plans for approval. The Commission’s decision was guided by the Appellee’s Muncipal Code criteria which included objectives such as harmony, avoidance of monotony and minimal accent with bright colors.
Synopsis of Rule of Law. Enforcement of vague standards like harmony, interest, depth and avoidance of monotony gave no meaningful guidance and constituted a deprivation of due process in the land use certification process.
Issue. Were the building design objectives contained in the City of Issaquah’s (Appellee’s) municipal code unconstitutional for vagueness in violation of due process? More particularly, were the building design objectives so vague or unclear that ordinary citizens would have to guess as to their meaning and would differ in how to apply these design objectives in violation of due process?
Held. The objectives were unconstitutional. Nothing in the objectives predicted whether the Commission would find the building interesting, monotonous or harmonious or in harmony. The Supreme Court of the United States (Supreme Court) found the vague code sections which gave no meaningful guidance to the Commission to be unconstitutional. The Supreme Court had not foreclosed the ability of city to control designs based on aesthetic values, however, the vague standards which amounted to review by the Commission on an ad hoc basis were a deprivation of due process.
The vagueness test does not require a statute to meet impossible standards of specificity.View Full Point of Law