## Facts

- A land trust owned about 215 acres in Edgartown within the RA-120 zoning district, bordering the Atlantic Ocean and Edgartown Great Pond.
- Edgartown’s zoning bylaw required a three-acre minimum lot size for residential lots in the RA-120 district, which comprised roughly half the town’s acreage.
- The RA-120 boundaries followed an environmental planning concept identifying large areas as fragile and suitable for conservation-oriented controls.
- The town supported the three-acre minimum as a measure to protect Edgartown Great Pond’s ecology by limiting nitrogen loading and related pollution from residential development.
- The trust sought a declaratory judgment that the three-acre minimum was arbitrary, unreasonable, and unrelated to any valid zoning objective, including claims that it was effectively exclusionary.
- The Land Court upheld the bylaw; the Supreme Judicial Court took direct appellate review.

## Issues

1. Whether the three-acre minimum lot-size requirement in the RA-120 district was shown, by a preponderance of the evidence, to be arbitrary and unreasonable or substantially unrelated to public safety, health, or general welfare under Mass. Gen. Laws ch. 240, § 14A.
2. Whether the trust proved the bylaw’s invalidity as applied to its land, given that its parcel lacked distinguishing characteristics relevant to the challenge.
3. Whether the lot-size requirement was invalid as exclusionary zoning based on the evidence presented.

## Decision

- The Supreme Judicial Court affirmed the Land Court’s judgment for the town.
- The court held the trust failed to prove, by a preponderance of the evidence, that the three-acre minimum was arbitrary, unreasonable, or substantially unrelated to public welfare.
- The court accepted evidence, including expert testimony, that larger lot sizes could reduce nitrogen impacts affecting drinking water and the adjacent coastal pond.
- The court rejected the argument that the Land Court failed to address an as-applied claim because the trust could prevail only by proving the requirement invalid in general on this record.
- The court found no persuasive evidence that the bylaw actually denied housing opportunities so as to establish an exclusionary-zoning violation.

## Legal Principles

- Zoning bylaws carry a presumption of validity; the challenger bears the burden to prove invalidity by a preponderance of the evidence.
- A minimum lot-size regulation is invalid only if shown to be arbitrary and unreasonable or substantially unrelated to the public safety, health, morals, or general welfare.
- Under Mass. Gen. Laws ch. 240, § 14A, the challenger must show invalidity as the bylaw affects its land; where the parcel is not materially distinguishable, the analysis may turn on the district-wide validity of the provision.
- Environmental protection, including safeguarding water quality and sensitive ecological resources from development impacts, is a legitimate zoning objective supporting large-lot requirements.
- Claims that large-lot zoning is exclusionary require evidence of actual exclusionary effect, not merely reduced development intensity.

## Conclusion

The court upheld Edgartown’s three-acre minimum lot size in the RA-120 district because the town’s environmental justification—protecting a vulnerable coastal pond from development-related nitrogen pollution—provided a substantial relation to public health and general welfare, and the landowner did not meet its burden to prove the bylaw arbitrary, unreasonable, or unlawfully exclusionary.


Johnson v. Town of Edgartown, 680 N.E.2d 37 (Mass. 1997)