## Facts

- A developer sought a permit to construct 10 low-rise “garden-type” apartment buildings on an approximately 15-acre tract in Baltimore City as a planned, unified development.
- Baltimore’s zoning ordinance defined a “lot” as a parcel “occupied or intended to be occupied by one building” and imposed minimum lot-area and yard requirements (front, side, and rear).
- The developer asserted the tract would remain in single ownership and operation, with no internal lot lines and no intent to subdivide or separately convey the buildings.
- A neighborhood improvement association opposed the permit, arguing the project must be treated as multiple buildings on multiple “lots,” requiring each hypothetical lot to satisfy minimum area and yard requirements independently.
- The Board of Municipal and Zoning Appeals approved the permit; the Baltimore City Court affirmed.

## Issues

1. Whether a multi-building garden-apartment project planned and maintained as a single development on one tract may be treated as a single “lot” for applying minimum lot-area and yard requirements.
2. Whether, under the proper characterization of the tract and the ordinance’s yard definitions, the project satisfied applicable front, side, and rear yard and lot-area requirements so the permit was valid.

## Decision

- The Court of Appeals affirmed the judgment upholding the Board’s approval of the permit.
- The court held that the unified garden-apartment development could be treated as a single zoning “lot” for area and yard calculations.
- Measuring required yards from the tract’s external boundaries (rather than from hypothetical internal lot lines), the court concluded the project complied with the ordinance’s yard and lot-area provisions.

## Legal Principles

- A multi-structure residential development may be treated as a single zoning lot when it is planned, owned, and intended to be operated as one integrated project without subdivision into separate building lots.
- Yard and open-space requirements tied to “the same lot with a building” may be measured with reference to the boundaries of the single tract treated as the lot, not fictional internal lines.
- Where a zoning board reasonably applies ordinance definitions to a proposed site plan in a technical layout and density dispute, appellate review will sustain the approval if consistent with the ordinance’s purposes and text.

## Conclusion

The court upheld the building permit, ruling that an integrated garden-apartment project on a single tract could be evaluated as one zoning lot and that, on that basis, the plan met the ordinance’s minimum lot-area and yard requirements.


Norwood Heights Improvement Ass’n v. Mayor & City Council of Balt., 191 Md. 155, 60 A.2d 192 (Md. 1948)