Brief Fact Summary. Stoyanoff seeks to build a house that is highly modernistic and unusual in design. The Architectural Board found the home was not in conformity with the style and design of surrounding structures, and refuses to issue the building permit.
Synopsis of Rule of Law. The city government’s delegation of authority to a non-elected Architectural Board was constitutional, even without very specific standards. “The Board shall disapprove the application if it determines that the proposed structure will constitute an unsightly, grotesque or unsuitable structure in appearance, detrimental to the welfare of surrounding property or residents…”
If by the term aesthetic considerations is meant a regard merely for outward appearances, for good taste in the matter of the beauty of the neighborhood itself, we do not observe any substantial reason for saying that such a consideration is not a matter of general welfare.View Full Point of Law
Issue. Whether the city government’s delegation of authority without very specific standards delegated to a non-elected Architectural Board was constitutional.
The Supreme Court reverses holding that the Trial Court erred in finding for Stoyanoff because the city ordinances were vague and therefore the delegation of authority was unconstitutional, denying due process. The Supreme Court held that the ordinances did in fact provide for clear rules based upon maintaining property values, finding that there was due process.
Discussion. The Architectural Board did not have specific standards to determine the conformity with proper architectural standards in appearance and design, rather the factors focused on the valuation of property values. There was a great amount of deference given to the committee to determine if the “appearance and design” conformed to housing in the area. The provisions were quite vague, nevertheless the court found them to be clear because of their focus on property values.