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State ex rel. Stoyanoff v. Berkeley

    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…”

    Facts. Stoyanoff seeks to build a house that is highly modernistic and unusual in design “but complied with all existing building and zoning regulations and ordinances of the City of Ladue, Missouri”.  The Architectural Board examines the application to determine if it conforms to proper architectural standards in appearance and design and found the home was not in conformity with the style and design of surrounding structures, and refuses to issue the building permit.

    Issue.  Whether the city government’s delegation of authority without very specific standards delegated to a non-elected Architectural Board was constitutional.

    Held.  

    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.


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