## Facts

- Briar Meadows Development, Inc. held options to purchase two adjoining tracts in South Centre Township: a 33.89-acre tract zoned Agricultural and a 91.5-acre tract split between Agricultural and Commercial, with roughly 21% in the Commercial district.
- The site was bordered by Interstate 80 to the north, an exit ramp and an adjoining owner to the east, State Route 11 and neighboring property (including Laura Baker’s) to the south, and State Route 1003 to the west.
- Briar filed a Municipalities Planning Code (MPC) curative amendment application seeking rezoning from Agricultural to Commercial/Industrial.
- Briar asserted the existing zoning was inconsistent with the comprehensive plan, improperly restricted reasonable commercial/industrial development, and amounted to illegal spot zoning.
- After hearings, the Township Board of Supervisors denied the curative amendment.
- On appeal, the court of common pleas allowed additional evidence; after procedural developments (including a stayed remand and an unsuccessful use-variance attempt), the court of common pleas took non-duplicative additional testimony, issued its own findings, and affirmed the Board.
- Briar appealed to the Commonwealth Court.

## Issues

1. Whether the court of common pleas failed to conduct the required de novo review by considering the Board record and referencing the Board’s prior findings.
2. Whether Agricultural zoning was invalid because it was inconsistent with the Township’s comprehensive plan.
3. Whether the Agricultural classification was arbitrary, unreasonable, or unrelated to public health, safety, and welfare (substantive due process/police power).
4. Whether the zoning constituted illegal spot zoning.

## Decision

- The Commonwealth Court affirmed the order of the court of common pleas.
- The trial court’s proceeding qualified as de novo review because it took additional non-duplicative evidence and issued independent findings and conclusions while also considering the Board record.
- Inconsistency with a comprehensive plan did not, by itself, invalidate the zoning classification.
- Briar did not carry its burden to overcome the presumption of validity by proving the Agricultural classification was arbitrary, confiscatory, or unrelated to legitimate police power objectives.
- The Agricultural zoning was not illegal spot zoning because it was consistent with surrounding uses and did not isolate the tract as an unjustified “island” of restrictive zoning.

## Legal Principles

- In an MPC land-use appeal requiring de novo review, a trial court may consider the existing municipal record, supplement it with additional evidence, and decide the matter based on the combined record, so long as it makes independent findings and conclusions.
- A municipal action is not invalid solely because it is inconsistent with a comprehensive plan; the plan is a policy guide rather than a self-executing regulatory standard.
- Zoning ordinances are presumed constitutional; the challenger bears a heavy burden to prove unreasonableness, arbitrariness, confiscation, or lack of substantial relation to public health, safety, and welfare.
- Illegal spot zoning requires an unjustified, isolated classification inconsistent with the overall zoning scheme and surrounding uses; similarity to adjacent land uses and rational planning justification defeats the claim.

## Conclusion

The Commonwealth Court upheld the denial of Briar’s curative amendment, holding that the trial court’s de novo process could rely on the municipal record plus non-duplicative additional evidence, that comprehensive plan inconsistency alone does not invalidate zoning, and that the Agricultural classification was neither unconstitutional nor illegal spot zoning.


Briar Meadows Dev., Inc. v. S. Centre Twp. Bd. of Supervisors, 2 A.3d 1303 (Pa. Commw. Ct. 2010)