## Facts

- The City of Bridgeport adopted zoning regulations creating multiple residence, business, and industrial districts.
- In 1937, the city created a Business Zone No. 3 district with specific requirements (including setbacks, open yards, parking, and limits on liquor sales).
- The neighborhood around Sylvan Avenue developed over time into a largely residential area on the city’s outskirts.
- Land along Sylvan Avenue had previously been zoned for business, but in 1936 it was reclassified to Residence A, while surrounding territory remained residential.
- Rome owned a lot on Sylvan Avenue (approximately 125 feet frontage and 133 feet deep) and petitioned to rezone it from Residence A to Business No. 3.
- Rome sought to construct a commercial building intended to house neighborhood retail uses (including a drugstore, grocery, hardware store, bakery, and beauty parlor).
- Some nearby residents opposed the change, arguing it would disrupt the residential character and was unnecessary.
- The zoning commission approved the rezoning, citing a broader policy of creating neighborhood business centers to reduce downtown congestion and relieve traffic.

## Issues

1. Whether reclassifying a single lot from a residential zone to Business No. 3 was unlawful “spot zoning” because it granted special privileges inconsistent with zoning “in accordance with a comprehensive plan.”
2. Whether the zoning commission abused its discretion by granting the rezoning despite neighborhood opposition and claims of harm to the residential area.

## Decision

- The Supreme Court of Errors of Connecticut set aside the trial court’s judgment sustaining the neighbors’ appeal.
- The court held the rezoning did not constitute unlawful spot zoning.
- The court held the commission acted within its authority and did not abuse its discretion.
- The case was remanded with direction to dismiss the administrative appeal.

## Legal Principles

- Zoning actions must be made “in accordance with a comprehensive plan.”
- Preferential treatment for a single lot or small area is generally disfavored and is valid only when taken in furtherance of a properly adopted plan serving the community as a whole.
- Allowing limited business uses within or adjacent to residential areas can be consistent with a comprehensive plan and is not invalid unless the action is arbitrary, unreasonable, or contrary to law.
- Neighborhood opposition, even if substantial, does not remove the commission’s power to act; the commission must consider the general welfare beyond localized interests.
- Courts review zoning determinations deferentially and will not substitute their judgment for the commission’s absent illegality or clearly arbitrary or unreasonable action.

## Conclusion

A single-parcel rezoning is not automatically impermissible spot zoning; it is valid when reasonably connected to an overall municipal planning program and supported by nonarbitrary judgment aimed at the general welfare, warranting judicial deference to the zoning commission’s discretion.


Bartram v. Zoning Comm’n of City of Bridgeport, 136 Conn. 89, 68 A.2d 308 (1949)