Loftin v. Langsdon

Loftin (plaintiff) purchased a large parcel of land in Maury County. The parcel had a 60-foot easement for a driveway or lane, but the parcel had only a narrow lane at the time of purchase. Loftin made major improvements to the parcel before subdividing the parcel into 18 separate lots. Loftin cleared and graded the lane, dug drainage ditches, installed a water pipe, and arranged for utility poles and a power line to be installed. After making these improvements, Loftin advertised the lots as good building sites with access to city water and electricity for sale. Loftin’s plans caught the attention of the director of Community Development for Maury County, Judy Langsdon (defendant) because Loftin had designated the easement as Beasley Lane on the map of the land for sale in his newspaper advertisement. Langsdon assumed Loftin had constructed a new road, so she believed that Loftin’s subdivision was subject to the local planning commission’s subdivision regulations. Reaching out to Loftin, Langsdon advised Loftin that he needed planning-commission approval before selling the lots. Consequently, Loftin brought an action for a declaratory judgment that his subdivision of the lots was not subject to the planning commission’s subdivision regulations. Loftin and Langsdon agreed that the approval of the planning commission was necessary if the subdivision required new street or utility construction. At trial, Loftin argued that he made the improvements to the parcel voluntarily and that no law required him to make such improvements to his land, so the subdivision regulations, which apply only if new street or utility construction is required, did not apply to his voluntary actions. Langsdon argued that the improvements that Loftin made were required to make the land usable, thus triggering application of the subdivision regulations. The trial court entered judgment for Loftin. Langsdon appealed.