Johnson v. Town of Edgartown

The town of Edgartown (defendant), on the island of Martha’s Vineyard, adopted a revised zoning bylaw in 1973 that established minimum-lot requirements ranging from 5,000 square feet to three acres. As a result of the bylaw, about one-half of the town was zoned for three-acre lots. Landowners in Edgartown and the trustees of the Herring Creek Farm Trust (the landowners) (plaintiffs) owned 215 acres zoned for three-acre residential lots. The landowners sought a declaratory judgment that the three-acre-lot requirement was exclusionary, arbitrary, and unreasonable because it did not advance a valid zoning objective. Edgartown argued that the three-acre-lot requirement was necessary to protect the ecology of Edgartown Great Pond (the pond) and control nutrient pollution from excess nitrogen that could make the pond unhealthy. Edgartown also asserted that the three-acre-lot requirement protected the town’s rural-resort character, which promoted tourism and helped the town remain economically stable. Additionally, the Massachusetts legislature had established a regional and statewide interest in preserving Martha’s Vineyard’s natural, historical, ecological, scientific, and cultural value, which could be damaged by inappropriate land use. The judge concluded that the zoning bylaw served a permissible public purpose and did not violate any constitutional or statutory provisions. The landowners filed a direct appeal to the state supreme court, alleging that the bylaw was not substantially related to the public interest.