## Facts

- A developer proposed converting approximately 780 acres of largely undeveloped farmland and wetlands in southern Teton County, Idaho into a planned unit development (PUD) featuring a golf course and a residential resort community.
- The proposed build-out included recreational amenities and mixed lodging and residential components, including a hotel, overnight units, and multiple categories of residential lots.
- The acreage was owned by several private landowners; about 140 acres lay within an unincorporated “Area of City Impact” near the City of Victor.
- The developer applied for (1) PUD approval, (2) a zone change from A–2.5 (agricultural) to R–1 (residential), and (3) approval of the Phase I final plat.
- The Teton County Planning and Zoning Commission held a public hearing and recommended approval with conditions.
- The Teton County Board of County Commissioners approved the PUD, the rezoning, and the Phase I final plat.
- Nearby landowners challenged the approvals, alleging violations of the county zoning ordinance, subdivision ordinance, and comprehensive plan, including claims about incompatible uses, allegedly prohibited PUD types in the prior zone, and excessive density.

## Issues

1. Whether the Board unlawfully approved the PUD, rezoning, and Phase I final plat by violating applicable county zoning and subdivision ordinances.
2. Whether the approvals were unlawful because they were inconsistent with the county comprehensive plan, including its density and land-use policies.

## Decision

- The Idaho Supreme Court affirmed the district court’s decision, which had affirmed the Board’s approvals.
- The Court held that the Board did not violate the county zoning or subdivision ordinances in approving the PUD, zone change, and final plat.
- The Court held that the approvals were not unlawfully inconsistent with the county comprehensive plan.
- The Court concluded the Board’s findings and determinations were supported by substantial and competent evidence, and the reviewing courts would not reweigh conflicting evidence.

## Legal Principles

- On judicial review of local land-use decisions, the reviewing court evaluates whether the decision is supported by substantial and competent evidence and is not contrary to law.
- A local governing body is generally entitled to deference in reasonably interpreting and applying its own zoning and subdivision ordinances, so long as the interpretation is not inconsistent with the ordinance text or governing law.
- A comprehensive plan serves as a guiding policy document and does not, by itself, regulate land use in the manner of an ordinance; it is implemented through duly adopted zoning and subdivision regulations.
- Alleged conflicts with a comprehensive plan do not invalidate a land-use approval where the local authority considered the plan, made supporting findings, and acted within the bounds of applicable ordinances and record evidence.
- Resolving factual disputes and weighing competing evidence about impacts and compatibility is primarily the function of the local decision-maker, not the reviewing court.

## Conclusion

The Idaho Supreme Court upheld Teton County’s approval of the development’s PUD, rezoning, and Phase I plat, holding that the Board reasonably interpreted and applied its land-use ordinances, adequately considered the comprehensive plan as policy guidance, and made findings supported by substantial evidence.


Evans v. Teton Cnty., 73 P.3d 84 (Idaho 2003)