## Facts

- Georgetown University’s main campus is about 104 acres within the Georgetown Historic District, bordering the residential Burleith and Hillandale neighborhoods.
- A 1990 campus plan set a full-time enrollment cap of 5,627 students.
- For its 2000–2010 campus plan, Georgetown proposed constructing a 780-bed on-campus dormitory (the Southwest Quadrangle) to reduce off-campus student residency.
- Georgetown sought approval to increase the enrollment cap by 389 students (to 6,016), effective only after the new dormitory opened.
- Neighborhood groups and residents complained of off-campus student impacts, including noise, disruptive conduct, parking congestion, and poorly maintained properties.
- The Board of Zoning Adjustment (BZA) approved the 2000–2010 campus plan but imposed nineteen conditions, including maintaining the prior 1990 enrollment cap through the plan period and additional conditions addressing student conduct and off-campus impacts.
- Georgetown petitioned for review, challenging the enrollment freeze and several behavior- and administration-oriented conditions as unsupported by substantial evidence and beyond the BZA’s authority.

## Issues

1. Whether substantial evidence supported the BZA’s decision to maintain Georgetown’s full-time enrollment cap at the 1990 level through the 2000–2010 campus plan.
2. Whether the BZA acted within its zoning authority in imposing conditions regulating student conduct and off-campus behavior.
3. Whether certain conditions unlawfully intruded into internal university administration rather than addressing land-use impacts.

## Decision

- The court vacated the BZA’s order approving the campus plan and remanded for further proceedings.
- The court held that the enrollment-freeze condition was not supported by substantial evidence in the administrative record.
- The court concluded that several contested conditions were arbitrary and capricious because they were insufficiently tied to evidence-based land-use impacts and extended beyond the BZA’s proper zoning function.

## Legal Principles

- Zoning decisions and conditions must be supported by substantial evidence in the administrative record.
- An agency must provide a rational connection between its factual findings and the conditions imposed.
- A zoning authority may address adverse neighborhood impacts through land-use regulation, but may not impose conditions that function as general social control or detailed governance of institutional operations.
- Conditions that lack an evidentiary basis or exceed statutory zoning authority are arbitrary and capricious and must be set aside.

## Conclusion

The court required the BZA to justify campus-plan conditions with substantial evidence and to confine its remedies to land-use regulation, vacating an extended enrollment freeze and other conditions that were not adequately supported or that improperly regulated student conduct and university administration.


President & Dirs. of Georgetown Coll. v. D.C. Bd. of Zoning Adjustment, 837 A.2d 58 (D.C. 2003)