Geisler v. City Council of Cedar Falls

769 N.W.2d 162 (2009)

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Geisler v. City Council of Cedar Falls

Iowa Supreme Court
769 N.W.2d 162 (2009)

Facts

In 2004, Michael Geisler (plaintiff) bought real estate in Cedar Falls, Iowa on which he planned to develop an apartment complex. In May 2005, Geisler submitted a site plan for the apartment complex to the Cedar Falls Planning and Zoning Commission (the commission). The site plan met all applicable ordinance requirements, but the commission denied approval of the plan due to significant public opposition. On May 23, 2005, the City Council of Cedar Falls (the city council) (defendant) denied approval of the site plan because it was inconsistent with the surrounding neighborhood in scale and character. At the same council meeting, a motion passed to discuss a moratorium to study the issue of the construction of apartment complexes in the overlay district where Geisler’s property was located. On June 13, 2005, Geisler submitted a revised site plan to the city development department. That same day, the city council imposed a moratorium on all development or construction of multi-family housing in the overlay district without discussing Geisler’s plan because it had not been processed in time. City officials subsequently refused to consider the revised site plan. In December 2005, the city council passed an ordinance prohibiting all development or construction of multi-family housing in the overlay district. Geisler challenged the city council’s decision in district court, alleging that the city had illegally denied his site plan. The court found that the new ordinance prohibiting construction of multi-family housing had been pending at the time Geisler submitted his site plan, applied the pending ordinance, and found that the city’s denial had been legal. Geisler appealed to the Iowa Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Baker, J.)

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