Bower Associates v. Town of Pleasant Valley

Bower Associates (Bower) was a housing developer that owned 91 acres, 88 in the Town of Poughkeepsie and three in the Town of Pleasant Valley (defendant), that it sought to subdivide and construct several single-family homes and townhouses on. Bower applied to the Pleasant Valley planning board for permission to subdivide its three acres. Pleasant Valley denied Bower’s application, citing environmental concerns. Bower challenged the decision, and the supreme court found that the planning board’s decisions were arbitrary and driven by community pressure because Bower’s subdivision would not provide the town with tax benefits. The supreme court found that Bower had met all conditions needed for approval of its application and directed approval. Bower commenced a civil-rights action under 42 U.S.C. § 1983 against Pleasant Valley alleging a denial of substantive due process and equal protection. The supreme court denied Pleasant Valley’s motion to dismiss, but Pleasant Valley appealed, and the appellate court reversed and dismissed Bower’s constitutional claims. Home Depot, U.S.A., Inc. (Home Depot) sought to develop a retail establishment in the Village of Port Chester, which bordered the City of Rye (defendant) in Westchester County, and sought a road-widening permit. Rye demanded that Home Depot impose traffic-mitigating measures, and the county would not approve Home Depot’s permit without Rye’s approval. Rye refused to consent to the permit. Home Depot brought suit in the supreme court, and the court found Rye’s actions were arbitrary and capricious and annulled Rye’s denial of the permit. Rye appealed, and the appellate court affirmed the annulment. Bower and Home Depot (plaintiffs) claimed they were deprived of constitutional protections when they were wrongfully denied land-use-permit applications. Bower and Home Depot sought damages under 42 U.S.C § 1983 for the delays caused by the wrongdoing. The appellate court concluded there were no constitutional violations and the complaints should be dismissed.