Steel Hill Development, Inc. v. Town of Sanbornton

In the 1970s, tourism to New Hampshire increased as a result of the completion of Interstate Highway 93. The town of Sanbornton (the town) (defendant) experienced a rise in popularity because of its proximity to lake and ski destinations. Steel Hill Development, Inc. (Steel Hill) (plaintiff) sought to take advantage of the opportunity and planned to build 500 or more homes in the area. Steel Hill purchase 510 acres in 1969. Until 1971, the Steel Hill tract was zoned as general residence and agricultural, requiring a minimum lot size of approximately three-fourths of an acre. Wanting to construct a cluster, or conventional, lot layout, Steel Mill began discussing negotiations with the town planning board. The town approved 37 lot plans meeting the three-fourths requirement. Due to heightened public interest in the use of land in the area, the planning board passed amendments to the zoning ordinance to enlarge the forest conservation areas, establish separate general residential and agricultural districts, and increase minimum-acreage requirements. The minimum-acreage requirements were imposed to restrict population growth, preserve the character of the town, and allow the town time to properly balance ecological and population pressures. The amendments resulted in 70 percent of Steel Hill’s land zoned in the forest district and 30 percent in the agricultural district, making the minimum lot either six or three acres and thus rendering the cluster zoning plan impossible. Steel Hill filed suit in district court and alleged that the lot-size requirements were unconstitutional because they were unrelated to the health, safety, morals, or general welfare of the community. The district court ruled in favor of the town.