HomeMy WebLinkAboutItem #04 - First Reading Ordinance1'7
llonorable Members bets of the
City Commission
r*8 201975
Substance Abuse Facilities
Amendments to Comprehensive
/,-J.y,+,..�tnrt..1. C,J— , Zoning Ordinance
P. W. Andretvs
City Manager
The Miami City Commission at their November 21, 1973, meeting directed
the Administration to conduct a zoning study of Drug Rehabilitation Centers
to determine their appropriateness \ ithin certain zoning classifications of
the Comprehensive Zoning Ordinance.
In response to this request, the Planning Department with the aid of an
appointed committee on substance abuse prepared a study entitled "Drug
Rehabilitation Centers Zoning Study." Study recommendations were evaluated
at two Planning Advisory Board workshop meetings and reviewed two public
hearings prior to consideration for adoption. The advisory committee at
an open meeting on January 6, 1975, adopted and transmitted to the Planning
Advisory Board its final draft of these amendments.
On February 5, 1975, the Planning Advisory Board at their meeting adopted
amendments to the Comprehensive Zoning Ordinance which places their loca-
tion in certain zoning classifications, provides standards for their appropriate-
nes c and recommends the establishment of an appointed committee on Substance
Abuse to review application.;.
Specific amendments adopted include:
definition of facilities by type and function providing for residential
and non-residential modes. The addition of seven (7) new terms to
the Zoning Ordinance specifically describes major rehabilitation
functions.
the processing of all future residential facilities only as Conditional
Use commencing in the R -2 (two-family district) and in succeeding
districts through the C-3 district.
the processing of each residential applicati gild rt�gl,irr_,•.�..,,
by an appointed committee on Substance AbJ�t'l}Ftg}Cliliii
its recommendation to the City Zoning Boa71, ... T. ti,„
Pages 1 of 2
_
MAR 1 21975
a _
hE•iU1NG
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HIonorable ,len-lbers of the City- e:onir,i• iun
to guide the Committee and the Zoning Board in its deterntinat.ion
on the appropriateness of e itablishing residential facilities a set
of minimum standards would he applied. Standards adopted include:
minimum lot size, housing, location, yards, parking, open space,
landscaping, proximity to support services, ingress and egress and
expansion,
non-residential facilities would be permitted first in the B-4 district
upon conditional use and as permitted nse in the C-Districts.
However, prior to the granting of a certificate of use or occupancy
each non-residential facility would be reviewed by an appointed corn-
mittee on substance abuse.
In recognition of the diverse nature of various residential based treatment
programs such as work release, mental retardation, etc. , the Planning Depart-
ment is currently preparing a comprehensive zoning legislation that will en-
compass all community based treatment facilities. Workshops on this legislation
have been scheduled for the months of March and April at the Planning Advisory
Board.
Page 2 of 2
Honorable City
Attentions Mr.
City of Miami,
Gentlemen:
Commission
P, W, Andrews
Florida
February 14, 1975
SUBSTANCE ABUSE
Re: ORDINANCE AMENDMENT = RECOMMENDED
Ordinance No. 6871, ARTICLE II,
ARTICLE IV, ARTICLE VI, ARTICLE
VIII, AND ARTICLE XII
Initiated by Planning Department
The Miami Planning Advisory Board, at its meeting of February 5, 1975,
Item #1, following an advertised Hearing, adopted Resolution No.
PAB 7-75 by a 7 to 0 vote Recommending an Amendment to the City of
Miami Zoning Ordinance No. 6871, by deleting, substituting and/or
adding new Sections to ARTICLE II, ARTICLE IV, ARTICLE VI, ARTICLE
VIII, AND ARTICLE XII, as set forth in the Planning Department's
recommendations on Pages 2 thru 5 of the attached Minutes dated
2/5/75.
An ORDINANCE to provide for the above has been prepared by the City
Attorney's office and submitted for consideration of the City
Commission.
cm
Attached: Minutes
cc: Law Department
Tentative City Commission date:
Sincerel ,
IfY
vim+.
David Simpson, Jr., irector
Department of Admin stration
Planning and Zoning Boards
March 13, 1975.
DRUG REHABILITATION
CENTERS
ZONING STUDY
PREPARED BY THE
CITY OF MI AMI PLANNING DEPARTMENT
AND THE
ADVISORY COMMITTEE ON SUBSTANCE ABUSE
JAN , 1974
PURPOSE
TABLE OF CONTENTS
ADVISORY COMMITTEE ON SUBSTANCE
ABUSE CENTERS
PROBLEM STATEMENT . .
SUMMARY OF FINDINGS
RECOMMENDATIONS
4
ANALYSIS OF EXISTING CONDITIONS 9
Land Use Relationships • • 9
Non -Zoning Controls 12
Zoning Controls 13
Location 13
Intensity of Use 15
Effects on Adjacent Properties is
Parking is
APPENDIX
Drug Abuse Treatment and Educational
Center Functional Types
Health Planning Council Position
"Residential Drug Abuse Treatment Facilities". ii
Eleemosynary Uses (Court Cases Abstracted
from Zoning Digest)
TABLES AND MAPS
Drug Arrests (incidence Nlap)
Substance Abuse Centers Survey 10
Location Map 11
Functional Type Map 14
Zoning Map It'
PURPOSE
The Miami City Commission at their November 21. 1973, meeting directed
the Administration to conduct a zoning study of Drug Rehabilitation Centers
to determine their appropriateness within certain zoning classifications of
the Comprehensive Zoning Ordinance.
To aid the Planning Department in its investigation, the City Manager appointed
a committee representing key social rehabilitation organizations together with
related City Department personnel.
This report titled "Drug Rehabilitation Centers Zoning Study" represents a
joint effort of the Planning Department and the Advisory Committee on
Substance Abuse.
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ADVISORY COMMITTEE ON SUBSTANCE ABUSE CENTERS
Committeemen
Dr. Ben Sheppard
Rev. Fred Harrison
lvl r. Charles Lincoln
Mr. Don Doyle
Mr. Frank Williams
Maj. Adam Klemkowski
Mr. George J. Acton. Jr.
Mr. Thomas A. Dooney
-2-
Representing
Director, St. Luke's Center
Spectrum Programs, Inc.
Comprehen:,ive Drug Abuse Progra►n
Comprehensive Alcohol Abuse &
Treatment Program
City of Miami Building Department
City of Miami Police Department
City of Miami Planning Department
City of Miami Planning Department
t-
i
PROBLEM STATEMENT~
The location of religious, philanthropic and eleemosynary uses has long been
a topic for debate among planning and zoning administrators. Early ordinances
permitted these uses throughout communities since they satisfied localized needs
_ and were in support of the community's health, welfare and safety. With time
and the changing nature of our cities these uses were found to present certain
nuisance features which questioned their presence within residential neighbor-
hoods. Churches once serving their immediate neighborhoods are new attracting
their former congregation from the suburbs. This phenomenon has produced an.
array of incompatible conditions. Likewise clubs, clinics, associations, hospitals.
schools (private and public) because of changing conditions have created similar
circumstances.
With a changing post-war society the need to provide a variety of public and
semi-public services heretofore unknown began to quickly make their presence.
Of the many new facilities that have emerged included are: the child care center,
elderly day center, social services centers, free clinics, counselling centers
for families, specialized private schools. halfway houses, homes for unwed
mothers, and residential rehabilitation centers for drug and alcohol abusers.
In recent years psychiatrists and social workers have found that. a successful
rehabilitation effort must stress the preservation of individual dignity. The
location of facilities designed to achieve this objective has been deemed most
appropriate in residential neighborhoods. It is here that the individual can
live and associate with local residents and assume responsibility, become an
active citizen and undergo a healthy transition during his rehabilitation.
Today, nearly all Substance Abuse Residential facilities are located in resi-
dential neighborhoods in Miami. In most instances they have operated within
the context of being good neighbors, alleviating any cause for complaint by
neighboring residents.
On November 21, Ice 3, Village South, a residential substance abuse center
appealed the adverse decision of the City Planning and Zoning Board to the
City Commission to permit their location in the R-2 and R-3 district under
Article IV, Section 36, General Provisions of the Zoning Ordinance. The City
Commission following an extensive hearing on this matter referred it to the
City Administration for evaluation and recommendation. During the past two
months the Planning Department with the aid of an Advisory Committee on
Substance Abuse met on several occasions to define the• problem of location and
pursue a course of action to provide for their future location.
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;=
I -SUMMARY Off` rttwINc S
Twenty=ohe substance abuse centers are located within the City of Miami.
Seven of these facilities function as residential establishments housing
approximately one hundred fifty (1q0) occupants.
The remaining fourteen facilities provide non-residential functions including
outpatient care, methadone maintenance, detoxification and compound
functions including education, referral and administration.
Geographically thr bulk of these establishments are located in the City's
north and northeastern neighborhoods.
With little exception, existing facilities are found in high substance abuse
areas.
Residential facilities are located principally in older residences ranging
in size from 6000 square feet to 11 acres.
Residential facilities house as few as .1 occupants to as many as 63
occupants.
The average residential facility has an occupancy of approximately 25
residents.
Research activities reveal that zoning provisions of other major cities
generally treat these (residential facilities) as Special Exceptions or
Conditional Uses.
-- Florida law provides appreciable literature governing their operation and
licensing.
40 OM
Residential centers appear to be good neighbors in view of minimal corn -
plaints from neighborhood residents.
-- Exclusion of residential centers from certain zoning districts can serve to
preclude services to portions of the substance abuse population.
The need for public awareness and support suggests requiring a hearing
process for all future centers (residential).
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DRUG ARRESTS
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11 — 20
21 — 50
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•— CHARGES — 1972
DRUG REHABILITATION CENTERS
ZONING STUDY
CITY OF MIAMI PLANNING DEPARTMENT • DEC., 1t373
1\111 F- l:
•
•
Preemption of residential centers in low density areas and requiring their
location in multiple residential districts appears restrictive from several
standpoints.
a1 Higher property costs associated with multiple residential zoning
properties.
b) Preemption from neighborhoods needing tac•ilities.
c) Restricted residential living environments in multiple districts.
The need for site development standards to govern residential substance
abuse facilities appears essential to both the neighborhood and facility
occupants' wellbeing.
-- The Conditional Use provisions of the Ordinance apnea r to provir.e the
most viable alternative for arriving at appropriateness.
The need to retain existing residential substance abuse facilities and to
provide the professional rehabilitation community the necessary latitude
for expansion and new facility establishment will require revision to the
Comprehensive Zoning Ordinance.
RECOMMENDATIONS 1
The Planning Department and the Advisory Committee on Substance Abuse
Centers recommend that Residential Substance Abuse Facilities designed to
provide a satisfactory living environment to its occupants be permitted upon
Conditional Use in all zoning districts excluding those districts for wholesale.
manufacturing and industrial activities.
In addition, it is recommended that a hearing and screening process be provided
to afford community residents an opportunity to understand the nature, function
and extent of services provided and to assure safeguards to both the occupant
and the community.
Provisions for other functional types of facilities which are non-residential in
nature are as follows:
Out -patient Facilities are deemed appropriate in all C-districts and should
be listed as a permitted use and as a conditional use in the R-4 district.
Methadone Maintenance Facilities are deemed appropriate in all C-districts
and should be listed as a permitted use and as a conditional use in the R-4
district.
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totliite Facilities are deemed appropriate in the R-CA, 11-C, and all
C-districts and should be listed as a permitted use.
Education and Information Facilities are deemed appropriate in all
C-districts.
.The specific amendments recommended are as follows:
Amend Article II, Definitions. by defining separately each Substance
Abuse Center by type corresponding to the Language contained in the
Florida Statutes. A listing of definitions is provided in the Appendix.
Amend Article IV, General Provisions. Section - Public and Semi-
Public Buildings or Uses.
4. Residential therapeutic facilities may be permitted in a1I zoning
classifications (excluding C-4, C-5. 1- t. I W-1) as a Conditional
Use. All residential therapeutic facilities prior to their consideration
for Conditional Use approval shall be reviewed by the Advisory Com-
mittee on Substance Abuse Centers, who may convene a public hearing
in the area in which the use is proposed. The Advisory Committee
shall submit its findings to the Zoning Board as supporting evidence
to determine the appropriateness of the proposed facility. The
Committee's findings in addition shall provide minimal standards
and safeguards designed to mutually satisfy the needs of the community
and the intended facility resident. Standards shall include but not be
limited to the following considerations: SITE SIZE. YARD AREAS,
PARKING, OPEN SPJ►CE, LANDSCAPING, PROXIMITY TO SUPPORT
SERVICES, AND INGRESS AND EGRESS, and other factors that may
have a bearing upon the appropriateness of such a facility.
Proposed standards for Residential Substance Abuse facilities: (These standards
should be adopted by reference since changing conditions may dictate later addi-
tions, revisions or modifications.) •
In R -1 and R - 2 zones -
Area standards
6000 sq. ft. -
12000 sq. ft.
18000 sq. it.
24000 sq. ft.
first 5 occupants
- 5-10 occupants
- 10-20 occupants
- 20 or more occupants
In R-3, R-4, R-5, R-C. C-1. C-.'. zones
minimum area - 10,000 sq. ft.
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Yard areaa in R=1 and R-2 zones
Parking
Open Space
Landscaping
rear 20 feet
side 10 feet
front 20 feet
In R=3, R-4, 13-5, R-C, C- I, C-2 zones
rear 20 feet
side min. 10 feet or 1Y%, lot width
front 20 feet
1 space for each staff member and 1 space for each 4
occupants. Waiver of occupant parking may be permitted
based upon this following factors:
'proximity to mass transit
*proximity to employment area
*proxitnity to community facilities
auto ownership and visitation policy
50 sq. ft. of open space shall be provided for each occupant.
Facilities within *proximity of public parks and open space
may be excepted from this provision.
1 shade tree for each 1000 sq. ft. of yard area shall be
provided. Where this provision is not met at the inception
of the facility's establishment other provisions for attaining
shade in open space areas where site occupants may be
afforded satisfactory outdoor spaces to pursue leisure time
activities may be considered.
Proximity to support services - Residential substance abuse facilities should be
located in *proximity to support services where auto and
travel time is reduced for the following essential services:
convenience shopping
medical and health facilities
cultural and educational facilities
entertainment
employment
park and open space
Proximity is defined as being no more than 1000 feel from the subject facility.
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Ingress and egress Drives for ingress and egress shall be restricted to no
more than me drive for each 50 feet of frontage,
ANALYSIS OF EXISTING CONDITIONS
The Planning Department with the aid of the Advisory Committee conducted
a survey of substance abuse facilities during the month of January 1074.
Approximately twenty-one facilities or centers were in existence.
The location of these facilities were found to be principally in older, transitional
neighborhoods in northwest and Central Miami. The desire for proximity to
residential arras has caused most of those in existence to situate within resi-
dential areas. Fourteen are located in R -districts, of which three arc in low
density districts. with the remaining seven located in C-districts. All of the
facilities are located adjacent to residential areas or in proximity to them.
In order to gain greater insight into what conditions and/or problems associated
with location, a sample survey was conducted. Each of the sampled facilities
were observed in the field to gain an impression of their relative impact on the
area in which they are located.
Land Use Relationships
The major land use problems associated with these facilities and particularly
the residential types were determined to be:
1. Inadequate site area - Several facilities were found to have inadequate
site area as a result of original deficiencies. This matter is viewed
to be one of serious concern as it affects the wellbeing of the occupant.
2. Unsatisfactory Location - Poor location is another apparent problem
of several facilities. To appropriately support the optimum func-
tioning of these facilities and their occupants certain critical location
standards should be adhered to. These include:
proximity to employment
proximity to schools
proximity to open space
proximity to transit
Many of the facilities are located in transitional or declining neighbor-
hoods whose image does not afford an optimum atmosphere to persons
undergoing rehabilitation.
_9_
M a p
Itidicatot Watt e
TABLE 1
DRUG REHABILItA''t't0N CENTERS SURVEY
Functional Zoning Permitted
Type District Use.
1 Concept House t Residential R-3 C -1 (It -4 Cond. )
2. Switchboard of Miami Hotline R-2 12 -C',A
3. Spectrum Outpatient C -2 12 -CA
4. Spectrum -Chase Residential R -3 C -1 (I2 -4 Cond. )
5. Spectrum -Dade Residential R-3 C-t (It-4 Cond. )
6. St. Luke's Methadone 12 -4 . 12-CA, R-C (R-4 Cond ')
7. Turning Point Outpatient 12-3 R-CA, R-C (R-4 Cond. )
8. Dodge Hospital Detox. R-4 C-1 (R-4 Cond.)
9. Black Cross Educational C-2 R -CA
10. Veterans' Admin. Residential R-C C-1 (12-4 Cond. )
11. Veterans' Admin. Methadone R -C C -1 (12-4 Cond.)
12. Village South Res. -Outpatient R-2, R-3 C-1 (12-4 Cond )
13. Jackson IVI2thadone 12-3 C-1 (R-4 Cond )
14. Jackson Detox. 12-3 C-1 (R-4 Cond )
15. Central Methadone C-2 R-CA
16. LaCasa Abierta Outpatient C-2 R-CA
17. Encuent ro Out patient C -4 It -CA
18. Model Cities Educational R -2 12 -CA
1Q. Genesis II Residential 12-CB C-1 (R-4 Cond )
20. Concept II Residential C-4 C-1 (R-4 Cond)
21. Unity House Outpatient C- 1 C- 1 (R-4 Cond)
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BIRO tO - I
LOCATION MAP
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11 7
DRUG REHABILITATION CENTERS
ZONING STUDY
0
CITY OF MIAMI PLANNING OEPAFaTMENT • DEC., 1373 Mll.l FS N
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1'
Itiadecriatr Parking - While many facilities were found to be free of
this problem, the Department. feels that there exists sufficient evidence
to warrant the adoption of minimum parking standards.
There are at present, two major types of public controls over the establishment
of substance abuse facilities: Non -Zoning and Zoning Controls:
Non- Zoning Controls
Substance abuse centers, being places of public issembly. ire regulated by
the City Fire Code. Housing Ordinance anal legis ation provided by the State of
Florida.
The rehabilitation of substance abusers in the State of Florida his received
substantial legislative action. Major legislation enacted. providing for their
function, include Gha.pter 397 of the Florida Statutes "Rehabilitation of Drug
Dependents."
The purpose and content- of Chapter 397, "Rehabilitation of Drug Dependents"
is to encourage the fullest possible exploration of ways by whit:I, the true facts
concerning drug abuse and dependence may be made known generally and to
provide a coml:>rchenr.ive program of htiioan research for dru1 dependents in
rehabilitation ( enters and after care programs. The Act roe-tni res licensing of
each center with annual renewal mandatory. To satisfy facilitating as bread
a program for providing these services the legislation make': reference to
several princip;,l facilities to carry out these services. In general these
facilities are referred to as "DATE centers" or Drug Abuse Treatment and
Education centers. They include:
Residential Ret' hilitation Centers are live-in facilities operating twenty-
four hours a diy, seven days a week, staffed by professional and para-
professional persons offering therapeutic programs for drug dependent
per sons.
Educational information center is an information center facility offering
education and information to drug dependent persons, their families, and
the general community.
Communications center or rap house is a program oriented toward youth
with the goal of prevention of drug dependency. Such a center may make
referrals to appropriate treatment facilities.
Methadone maintenance program is the scheduled administration of
methadone under the investigative new drug permit issued by the FDA
and the U. S. Justice Department in a program providing supportive
rehabilitation services such as counseling, therapy and vocational
rehabilitation.
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.AA
Zoning Controls
The requirements specified by State legislation, while exacting and comprehensive
as to operation and performance, provide no standards for site requirements, off,
street parking, or neighborhood location. $ecause of local circumstances, provi-
sion for the proper control of these facilities is viewed as being best obtained
under local zoning ordinances.
Zoning can regulate Substance Abuse Facilities within a community. Principally
zoning can regulate: location, density and intensity of use, effects on adjacent
properties and parking. The City of Miami Comprehensive Zoning Ordinance
provides within certain zoning classifications hospitals, clinics, .convalescent
homes, nursing homes, medical facilities and institutions for the aged, indigent
and infirm, Classifications allowing for the above mentioned facilities as a
permitted use (excluding clinics which are permitted in the RC -A district) include
the following commercial districts: C-1, C-2 and C-3. Upon conditional use the
ordinance provides for their locating in the R-4 district following appropriate
public hearing and the establishment of appropriate conditions,.
A survey of existing residential facilities providing rehabilitation to the substance
abuser reveals, that all existing facilities are located within districts in which the
use is permitted only upon Conditional Use, which has not been provided or are
located in a district which does not permit their establishment. Several out-
patient facilities and educational and hotline facilities are not in compliance with
the provisions of the ordinance.
Location
The location of Substance Abuse Facilities can be restricted to certain zoning
districts. At present, the Zoning Ordinance allows these uses in R-4 (on condition)
and C-districts of the City.
In the opinion of the Planning Department and Advisory Board, facilities providing
residential rehabilitation care belong in residential districts. These activities
are members of that group of facilities which are intimately associated with home
life. Occupants demand open space, sunlight and air, quiet surroundings, freedom
from heavy vehicular traffic, an environment of serenity and safety and in proximity
to their families, friends, jobs and cultural pursuits.
It must be recognized, of course, that there are certain features of these facilities
that require careful attention in terms of their relationship to adjoining residential
areas. Two major features attendant with the location of Substance Abuse Centers
in the residential neighborhood are: noise and parking. Unless both of these
factors are controlled, the image and effectiveness of the facility can and will
produce serious hardships to neighboring residents.
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FUNCTIONAL TYPE
* RESIDENTIAL- ( REHABILITATION )
• OUT PATIENT
DETOXIFICATION
o METHADONE MAINTENANCE
• HOTLINE
A EDUCATIONAL
DRUG REHABILITATION CENTERS
ZONING STUDY
CITY OF MIAMI PLANNING DEPARTMENT • DEC.. 1973
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MILES
With regard to the recommendations covering location, a distinction should be
made between "residential and non-residential. The tatter, in effect, is a
commercial activity which should be located in a like district. It is recort
mended that residential facilities be prohibited in the industrial districts because
of the deviation in compatibility with uses found in these districts, especially
those which may contribute to the occupant's physical harm or affect his image
and self=worth.
Intensity of Use
The intensity of use of land can be controlled in the Zoning Ordinance by regulating
occupant density. Density is controlled by three factors: lot area, usable open
space, and facility capacity. At present, the Zoning Ordinance directly controls
only the minimum lot area and this corresponds with the district's controls.
It is recommended that controls over occupant density be specifically stated in
the form of lot area and open space especially in low density districts.
Effects on Adjacent Properties
While the aforementioned areas of control, location, and intensity of uses are
regulated because of effects on adjacent properties, the more direct form of
control is through the inclusion of buffer devices. The Planning Department
believes this form of control, employing yard requirements to offset sound
levels or through the requirement that a wall be provided where existing building
locations make the yard requirements prohibitive.
Parking
Parking regulations associated with these facilities are observed as being
important. In view of the average facility size, 25 occupants and staff size
(4), parking standards should correspond with the occupant/staff demand.
Provisions for waiving parking where circumstances exist may warrant such
action and should be considered; however, available space should be retained
in open space should future needs arise.
In summary, the kinds of controls contained in the aforementioned recommendations
will serve to lessen the annoyance features of these facilities and enable them to
assume their rightful place in the neighborhood where, under the controls outlined,
a satisfactory environment for rehabilitation without harm to the community may
result.
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SAW cLSt
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41
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ZONING
• R-2
R-3
* R-4
▪ R—C /R-C-B
p C —I
• 0-2
O 0-4
swttSr.
DRUG REHABILITATION CENTERS
ZONING STUDY -16-
CITY OF MIAMI PLANNING DEPARTMENT • DEC., 1973 - MILES
APPENDIX
EDRuo AtausE TRE A ME N1- ; t EbucATIONAL.
CENTER F'UNCTI ONAL TAPES
i ESII)EN'1'TAIDRUG ABUSE: TREATMENT CL TEit.
DettriPtion
A residential treatment center is a lire-i'i facility which provides a 24 hour therapeutic regime
for the treatment of drug dependent persons. This involves a therapeutic environment staff-
ed by professionals and trained etc -addicts and paraprofessionals supervised by professionals.
METITADONE MAINTENANCE PROGIAMS
Description
A methadone program is one that utilizes methadone as a tool in the rehabilitation process of the
opiate addict. It provides the ancil;ary services of individual counseling, group counseling, voca-
tional training and placement, alternative pursuits, and other appropriate approaches that are
aimed at affecting positive life styles changes in the opiate addict.
HOT LINE
Description
A hotline is a telephone service that provides information and referral to individuals for a va-
riety of personal problems, including information about drugs, drug treatment facilities and emer-
gency treatment centers.
EDUCATIONAL PROGRAMS
Description
Drug education should develop attitudes toward life and toward one's self that makes drug
dependency unnecessary. The subordinate goal is to indicate consequences and alternatives to
drug use, as well as provide drug -specific information to youth, to the general public and
to the families of drug dependent persons so they may gain better understanding of the drug
culture and of the specific problems involved.
OUTPATIENT SERVICES
Description
Outpatient care is service provided to clients who are seen periodically at specified times in a
therapeutic setting.
RAP HOUSES
Description
A rap house is a youth -oriented program acting primarily as a reception center for drug involved
young people. It relies on the supportive service of peer involvement through "rap" sessions. It
provides referral to other social service and medical agencies. The facility may be a storefront,
house or building located within the social setting of the population served.
zCI1 Ci 'NIt11A11 'IILANN�tvf1' iul+Altt�w./vtt�
Comprehensive ��zrkullr 1i1.,iir 'aoll k. wti+s6T,I; r. Orr South Florida
trdctiaasl ••c „b+ittrrrt.ri-••.L;9it. CO?ZEs `"t{
3050 biscayre boulevard / `;ulth 6,11 / rlll.;nit. t14 l tcia 33137 ;/ phone 305 / b73-0220
04tt JAN 10197,1
BERNARDO BENES. PH.D.
PRESIDENT
W C MCCUE
E*EcuTIVE D,AECTON
BOARD OF DIRECTORS
MICHAEL ABRAMS
BERNARDO BENES PH D.
RUFUS RROADAWAY. M.D.
RAUL CUADRADO DR P. H
A. SUDO CUTLER
ANDREW DANN SR
WILLIAM O. DAVENPORT, M D.
JOYCE DIEFrENDERFER
EDWARD c GRAFTON
PEORO J GRFER M D.
JOHN C HARRISON
1•1ELVlN LEVITY
5 L. LICHTENrELD
PETER MASIKO. JR.. PH D
R HARDY MATHESON
CARRIE MEEK
FLORIDA MURRAY
LOUISA M MURRAY
WILLIS MURRAY
STANLEY C MYERS
ROPERT H. NEWMAN
CHARLES W. NOROWALL
L RUSSE.LL NORION
E M PAPrEti M D.
M ATHALIE RANGE
MORTON ROSENRLUTH. O D S.
MILTON 5. SASt AW. M.D.
MICHAEL SHORES
DON SHOEMAKER
ROBERT 5. SUMMERS
CHARLES F TATE. JR.. M.D.
CHARLOTTE TATRO, PH D.
ROBERT TRIMBLr
REGINALD R WALTERS
WINSTON W. WYNNE
MURRAY ZEOECK. O.O.
TO:
JOB Nh
t, y
NENO._ ✓,.,
Mayor Maurice'Vea r ; `CaiiiYiiiss oneirep:iCity Manager
Paul Andrews and Special Drug Abuse Rehabilitation
Zoning Committee of the City of Miami, County
Manager Ray Goode and Commissioners of Metropolitan
Dade County.
FROM: Health Planning Council Board of D' ct
Bernardo Benes, Ph.D., President
RB: Health Planning Council Hoard position relative
to the zoning of drug abuse rehabilitation
facilities.
On December 17, 1973, the Health Planning Council Board
of Directors adopted a position relative to the location
of residential drug abuse treatment facilities in Dade
County. The position taken by the Board is as follows:
The Health Planning Council supports the;Ipremise that
residential drug abuse facilities which house licensed
rehabilitation programs conforming to applicable safety
and health laws be permitted by right in all apartment,
rooming houses or more liberal zoning districts and in
other residential or more restrictive zones by approval
following a public hearing.
I hope that this position is taken into consideration
in any deliberations or reports you may have regarding
this matter.
Thank you.
ii
The Health Planning Council is a voluntary, non-profit organization dedi-
cated to assisting the community in identifying and meeting its health
neocis through reso.Irl-h, et)I'rllimitiltn, inrf'lnmr,nfittirjn.
f
ki.E
MOS.VNAR.4r SES
COUP? CASES AEIS1R AC'"f"Eb Fig ciM ThE 2:oNiNG t5i6e,
COVENANTS
HOME FOR MENTALLY !IMAM
The plaintiffs sought to enforce a protective covenant
restricting the use of lots in a subdivision to single-family
tesidential purposes. They claimed dekndiM violated this
restriction by operating a home for the mentally retarded.
The defendant claimed that her lot was not bound by the
restriction because it was not mentioned in her deed, that '
her actions did not violate the covenant, and that the
restriction was not enforceable because it was contrary to
public policy. The defendant showed that no more than six
persons were cared for in her home at one time, that she
received financial consideration from the state .or mainte-
nance of the home, that she was duly licensed by the state,
and that she was never informed of the restriction now
being imposed upon her when she purchased her home.
24 20 271
CALIFORNIA
The court rejected . all three of het contentions and
permanently enjoined further operation of the family=care
home. She had constructive notice of the restriction
because it had been included ir the original conveyance of
her property and failure to note it in the conveyance to het
was hot of any consequence. The court concluded that
evidence defendant was licensed by the state, was paid for
the care of each handicapped resident, and had two paid
employees in her home indicated that a business enterprise
was being carried on. A business is the "antonym" of
residential purposes and, the court continued, even a
regular boarding house would violate the restriction. As to
the defendant's last contention concerning public policy,
the court noted that the state had declared that it is the
established "statewide policy that the use of property for
the care of six or fewer mentally disordered or otherwise
handicapped persons is a residential use of such property
for the purposes of zoning." Welfare and institutions Code
§5115. The court found that this statement of policy only
worked to protect such an operation from the arbitrary
occlusion by a municipality through its zoning regulations
and concluded: "IS) uch an artificial and arbitrary attempt
by the state at redefinition of terms cannot impair private
contractual and property rights."
Seaton v. Clifford, Covet of Appeal of California, Second
District, Division 2 (intermediate count], Decided March
15, 1972, 100 Cal.Rptr. 779
Editorial Comment: Signalling a counterattack against
those who would erode private property rights, the Seaton
court characterized defendant's argument that the statutory
protection of group homes for the handicapped necessarily
applied to restrictive covenants as well as zoning ordinances
as an "artificial and arbitrary" attempt at the redefinition
of the term "residential." One could argue that the label
"arbitrary and artificial" applies with equal force to the
court's own interpretation of the term "residential."
Assuming that covenants restricting land to residential uses
have the same purpose as similar zoning regulations, i.e., the
protection of dwellings from incompatible uses, a Troup
home for less than six mentally retarded adults arguably has
few "indicia" of a non-residential use (which is a better
antonym for "residential" than "business"). The group
home that was the subject of the Seaton case apparently
looked like other single-family houses in Montalvo Heights.
There was no evidence that it was a source of environ-
mental pollution or that it generated excessive noise, light,
traffic, or parked cars. Nor does the court mention evidence
that the handicapped residents had become a nuisance to
their neighbors. Moreover, the court's emphasis on the
transiency of the group home's residents seems misplaced in
light of the record. The "indicia" of a "husiness" use relied
on by the court —state licensing, :mployees, and income —
could also be applied to a couple with a fuU-time maid who
received compensation for the care of foster children.
This arbitrary and artificial definition of the term "residen-
tial" appears to bear little relation to any demonstrable
externalities the group home may have imposed on its
neighbors. The danger is that such distinctions have the
force to exclude, no less than the most blatant snob zoning.
Courts should be more wary of recognizing a property right
to exclude a particular land use where the unspoken motive
may be to exclude a certain kind of resident.
In addition to these problems about the way in which the
Seaton court interpreted the private covenant, there are
also broader implication. arising from gratuitous remarks
about conflicts between public regulation and private rights
derived from covenants. The court seems to be saying that
if the state clearly enunciated a legislative policy that group
homes could not be excluded by operation of private
covenants, then such legislation would be unconstitutional
in light of the restriction against impairment of contracts.
The court indicates that exercise of the eminent domain
power, and not policy power regulation, would be appro-
priate to implement the group home policy, although it
does not say exactly what the state would have to
condemn. For a discussion of these broader issues, see
Berger, "Conflicts Between Zoning Ordinances and Restric-
tive Covenants: A Problem in Land -Use Policy," 43
Nebraska Law Review 449 (1964); and Comment, "The
Effect of Private Restrictive Covenants on the Exercise of
Public Powers of Zoning and Eminent Domain," 1963
Wisconsin Law Review 321,
•
NUISANCE
1-1ALPINAY HOUSE
A "halfway house" was established in a mixed business and
residential area to help recently released and soon to be
released convicts readjust to society. It was intended to
function as a "step between actual incarceration and full
return to society." Persons convicted of sex-, drug-, or
alcohol -related crimes were purportedly to be barred from
participation in "the house. Neighboring property owners
shut down the "halfway house" by obtaining a court
injunction against its operation, claiming it was a private
nuisance. On appeal this claim was sustained, since there
was sufficient evidence the house had diminished property
values, the residents had a "real and reasonable fear and
apprehension for their safety" in that a "sex offender"
resided there, and an incident had occurred which involved
the use of alcohol.
The appeals court distinguished this cafe from the Connec-
ticut case of Nicholson v. Connecticut Halfway House, 218
A.2d 383 (Conn. 1966). In the present case the halfway
house caused measurable and substantial injury to nearby
residents, while in the Connecticut case "there was only
apprehension of decrease in property values and no
evidence of any decrease in values of nearby property from
the proposed use of the property."
Arkansas Release Guidance Foundation v. Needier,
Supreme Court of Arkansas (highest courts, Decided March
20, 1972, 477 S.W.2d 821
Editorial Comment: This opinion is unfortunate for two
reasons: first, it is bad law. Second, that bad law throws
another legal obstacle in the path of a movement away
24 2C3 2
Aid KANSAS
from institutional treatment of various social and physical
disabilities Tiose who advocate this trend rejerf the total
separation of persons having such disabilities frofn "nor-
final" society and emphasize treatment and tehabilitation
within the community in which these pets Ott trust
eventually learn to function. The trend manifests itself in
the establishment of halfway houstt, group homes, foster
homes, and the like.
The zoning of the foundation's property was not an issue;
aoparently the use w is permitted in the mixed residential
a id commercial distict in question. In an earlier case,
Arkansas Release Guidance Foundation v. Hummel, 435
S.W.2d 774 (Ark. 1969)(reported at 21 ZD 114), the
Foundation Lost because it failed to prove it was a
"philanthropic" use permitted by the zoning ordinance.
Here, however, the neighbors brought a private nuisance
action against the halfway house.
The court enjoined what was essentially another residential
use because its neighbors felt that the kind of people who
lived there would be a nuisance. The only evidence the
neighbors offered to show that the use and enjoyment of
their property had been impaired was a loss of property
value. Would the Arkansas court receive as favorably a suit
to enjoin the sale of a home to a black family on the
grounds that neighboring property values were diminished?
Beyond actual harm, the court —unlike its brethren in
Connecticut —was ready to give credence to the plaintiffs'
unsubstantiated fears that the halfway house residents
would commit crimes. The court finds precedent for the
acceptance of this evidence in Arkansas cases enjoining
funeral parlors as private nuisances. No matter how well
established the notion may be in Arkansas that funeral
parlors are tantamount to a nuisance per se, its application
to the halfway house seems inapt. Funeral parlors are
clearly a non-residential use, and the accoutrements of the
undertaker's trade are admittedly offensive to the sensibil-
ities of many. But a halfway house and its inhabitants are
not such known quantities. If ex -convicts are to be treated
as nuisances because of what others believe, rightly or
wrongly, about them, where can they live?
NURSING HOME
City issued a building permit for the construction of an
addition to an existing home for the aged. Area residents
seeking to stop the expansion claimed the extension was
"in reality a separate building which, under the city zoning
ordinance, requires aseparate lot." Despite the fact that the
original plans filed for the project were for separate build-
ings, the court held that this was merely an expansion of an
existing building and not a separate building:
(T( he existing structure and the proposed wing are to
iv
24 ZD 203
PENNSYLVANIA
be physically connected to each other, have internal
access by hallways, share many common facilities, as
well as a common fire alarm system.... (SJ uch
"ready access from one part of the structure to
another"... is an extension and not a separate
building....
Stack v. Episcopal Residence, Inc., Commonwealth Court
of Pennsylvania (intermediate court], Decided January 10,
1972, 285 A.2d 925
EXCLUSIONARY ERAC ICES
bRUt TREATIVIENt CENTER
A hospital sponsated a methadone treatment clinic for dnig
addicts in the city's downtown business district. The toning
ordinance did not allow either hospital or clinics in this
district. After it opened, the commissioner of buildings
notified the owner of the store housing the methadone
clinic that this operation violated the toning laws. The
notice was ignored, and the city then oontntenced a
criminal prosecution against the owner -landlord and the
managing agent.
The defendants argued the ordinance was unconstitutional
because no zone expressly provided for a clinic, and the
clinic was similar to other uses permitted in the district.
Examining the second contention, the court rejected the
argument that a methodone clinic was similar to a research
laboratory, medical or dental offices, or facilities devoted
to scientific purposes.
Noting that the city could "create attractive and cohesive
24 ZU 305
NEW YORK
central business districts" under its toning laws, the court
found that within the immediate vicinity of the clinic thee
were located an urban renewal project, a bus terminal, a
railroad station, a tetail shopping area, and the streets of
the area were heavily congested during the day. Based on
the city's police power and the geographical location, the
court ruled that the exclusion of hospitals from the central
business district was not unreasonable or arbitrary.
Though no section of the zoning ordinance expressly
provided for clinics, the court said clinics were permitted in
any district which allowed hospitals, since clinics were an
accessory use. Finding the methodone center which treated
drug addicts as part of a hospital operation, the court held
the clinic violated the zoning laws.
People ex eel. D'lorio v. Alfa Realty Co., City Court of
Mount Veriron ftrial court], Decided March29, 1972, 330
NY.S.2d4C3 -
PUBLIC FACILITY 24 ZD 394
Drug Treatment Center NEW JERSEY
The state department of health announced its plan to
purchase a building previously used for a parochial school
to be used as a treatment center for drug addicts. The
property in question was located in an area zoned for
residential use and "the surrounding neighborhocrd is made
up of primarily one- or two-family residences, medical
offices, a church, a synagogue, and two elementary
schools." The plaintiff brought this action to enjoin
establishment of the treatment center on the grounds that
the state department of health lacked authority to operate
such a center and that the department was in violation of
the local zoning regulations. Finding that the department
had such authority, the court held that the state health
department was also immune from local zoning control.
Applying the rule in Rutgers, State University v. Piluso, 286
A.2d 697 (N.J. 1972)Ireported at 24 ZI) 1571 , that
immunity from local land -use regulation depends upon
legislative intent, the court found that:
Considering the extent of the present-day state-wide
drug problem and the policy consideration which
surrounded the enactment of [the drug control act],
together with all other pertinent factors, we conclude
that the legislature intended to cloak the department
with immunity from such local control.
However, such immunity is not absolute and the court will
consider whether it has been exercised in an arbitrary or
unreasonable manner. Here, there was some evidence that
the department completely disregarded the needs and
desires of the local governmental body and its citizens.
Thus, the court remanded the case for reconsideration of
the reasonablenes< or arbitrariness of the department's
selection of the land in question. It noted that the burden is
upon the plaintiffs to prove that the department acted in an
arbitrary and unreasonable manner.
Long Branch Division r. f United Civic and Taxpayers
Orga►rization v. Cowan, Superior Court of New Jersey,
Appellate Division [intermediate court], Decided May 30,
1972, 291 A.2d 381
GROUP HOME
Challenge to location of home for students alienated
from their parents in expensive single family residen-
tial district rejected because special permit issued in
conformity with ordinance and statute (Mass.), 418
Operation of private residence as group home for
mentally retarded violated covenant restricting use of
property for single-family purposes (Cal. App.), 271
Ordinance preventing rental of seasonal seashore dwell-
ings to groups of unrelated adults was invalid (N.j.), 6
v
Ordinance which prohibited families of more than five
unrelated persons from residing in single family
residence was valid (N.Y. trial), 145
Prior action contestin,l validity of certificate of occu-
pancy for drug rehabilitation center did not bar
action by adjacent property owners for damages
allegedly caused by violation of zoning ordinance
(Tex. App.), 494
HALFWAY HOUSE
Halfway house for ex -convicts enjoined on grounds it
constituted private nuisance (Ark), 269
25 221 WisCoNSIN
RESID€NttAL USES
Therapeutic Holmes tot Emotionally
bistutbed Children
Residences used for the housing and caring of
emotionally disturbed children wete not permitted as
of right in a single-family residential district since
such use did not come within the definition of family
under the toning ordinance. Such uses might be
allowed in Bich districts upon site approval, or upon
obtaining of a special permit or variance fro m the
board of adjustment.
Browndale International, Ltd. v. Board of Adjust-
ment for County of Dane, Supreme Court of
Wisconsin (bigbest court), Decided June 18, 1973,
208 N.W.2d 121
The plaintiff proposed to lease six homes on a 182•acre
parcel of property for the housing, care, and treatment of
emotionally disturbed children. The houses were grouped
together as a colony on one portion of the property and
would be run by a professional staff. The county supervisor
had determined that the proposed use would constitute
single-family dwellings within the meaning of the county
zoning ordinance. The board of adjustment reversed this,
but it was in turn reversed by the trial court which held
that the proposed homes would be single-family dwellings if
no more than five children lived in any one of them. Upon
appeal to the state supreme court, it was held that the
proposed homes would not constitute single-family dwell-
ings and were not permitted as of right on the proposed site.
The opinion was written by Justice Beilfuss.
The proposed home sites were located in an A-1 agricul-
tural district which permitted single-family detached dwell-
ings as of right. Other uses were permitted upon first
obtaining site approval. The zoning ordinance defined a
single-family dwelling as a "building designed, for and
occupied exclusively as a residence for one family." It
further defined family as "any number of individuals
related by blood or marriage, or not to exceed five (5)
persons not so related, living together on the premises as a
single housekeeping unit, including any domestic servants."
The proposed homes were designed to treat and care for
emotionally disturbed children who were either neglected,
dependent, or delinquent and placed in the homes by the
courts. These 'therapeutic homes' would contain front four
to eight children and be run by a professional staff of house
parents, social workers, and others. The homes were to be
licensed under a child welfare agency but were not operated
as foster homes or as a large institution. Upon appeal to this
court two essential issues were raised. First, what was the
nature of the scope of review by a court of the board of
adjustment's decision. Second, was the proposed use a
single-family use as defined in the county zoning ordinance.
On the scope of review, the supreme court concluded
that plaintiffs' contention that review was limited only to
the question of whether the board's decision was within its
jurisdiction and not based on an error of law was incorrect.
The reviewing court has the discretion to hear additional
vi
testimony or other evidence and to make additional
findings of fact and conclusions of law. The court noted
that the nature of review had been changed by statute to
allow a reviewing court to go outside the adtninistrative
body's record to consider additional evidence. Thus, even
though the supreme court reversed the trial court's decision
on other grounds, it held that the trial court "did not err by
taking additional evidence and basing its findings of fact
and conclusions of law, at least in part, upon such
evidence."
Next, the court noted that the issue before it in inter-
preting the meaning of a toning ordinance was a matter of
law and that it was not bound by the trial court's interpre-
tation. "The question then is whether these therapeutic
homes are single-family dwellings within the meaning of the
ordinance." The court concluded that they were not. They
were not to be occupied "exclusively as a residence." Their'
basic purpose was as a commercial enterprise. "The use of
the premises is not even principally for residential living
purposes. Rather, its primary use is to provide care and
treatmen: for emotionally disturbed children." The court
was influenced by the fact that a professional staff was
hired and that rehabilitative activities were to be carried on
at the sites. The coact noted:
The therapeutic home 'arrangement' is substantially
different than a group of priests, nurses, school
teachers, students or others who acquire premises to
use as a residence for a group.
The pr')twsed use was felt to defeat the intent of the zoning
ordinance and ignore the express words "occupied exclu-
sively as a residence for one family."
The court found that there were other means of estab-
lishing such uses in the county. "it cannot be reasonably
said that the board is atter:apting to thwart this method of
care and treatment for emotionally disturbed children. The
board has expressed no objection to the therapeutic home
idea but only justifiably refused to interpret the therapeutic
home as a single -fancily dwelling —especially in Tight of
Browndale's commercial attempt to colonize six homes in
one site area under the guise of designating them as single-
family dwellings."
The court also concluded that it was not a denial of
equal protection of the laws to permit foster homes as a
single-family dwelling while not permitting therapeutic
homes as such. The residential character of the foster home
does not depend upon the foster child, but has already been
determined to be such even without the foster child. The
parent, not the home, is the licensed body. With the thera-
peutic home, it is the home, not the parent, that is licensed.
Thus, the court affirmed the original decision of the
board of adjustment which had held that the proposed
homes were not single-family dwellings. It reversed the
decision of the trial court and remanded the case back to
the board pursuant to that body's original decision.
2520240 NSWVORK
HALFWAY HOUSE
Allowed by Special Exception
The plaintiff, a nonprofit corporation, operated two
halfway houses for mentally restored persons. One of the
premises was in an R-3 district and the other was in an R-2
district. it obtained a special exception for the house
located in the R-2 zone by a vote of four -to -two of the
board of zoning appeals. Its application for a similar special
exception for the house in the R-3 zone was denied by a
two -to -two vote of the board. It then instituted this action
for judicial review of the board's action.
The court found that the proposed use was allowed in
the R•3 zone as a co^valescent home by special exception
to be granted by the board "if it is found that such use will
not be injurious to the contiguous or surrounding property
and that the spirit of the ordinance shall be observed and
substantial justice done." A special exception is to be grant-
ed if the conditions set out in the ordinance are found to
exist, i.e., lack of injury to contiguous and surrounding
property. The board members voting to refuse the permit
failed to make findings along these lines which were sup-
portable by the evidence; their opposition was apparently
to any location of this type of use in the district at all. The
legislative body had determined the basic compatibility by
allowing for a special exception and that determination is
not to be ignored by the board. The court held that the
"proposed use is lawful and the findings which resulted in
the denial of the application are without support in the
evidence, are erroneous and arbitrary and arc annulled." It
directed that the plaintiff be issued a special exception for
operation of a halfway house for the mentally restored in
the R-3 district.
East finuse Corp. v. Riker, Supreme Court, Alonroe
County (trial courtJ, Decided January 11, 1973, 339
N.Y.S.2d 511
vii
25 2b 241 NEW YO R K
GFROt1P HOWIE
Prohibited in One -Family Residential
District
The city brought this action to enjoin the defendants
from using.a one -family residence located in a single-family
residential district as a group home pursuant to a state
social services law. The court held that the proposed group
home was not a permitted use in thr, city's one -family resi-
dential district, but staved enforcement of its judgment
"pending application by defendants to the Zoning Board of
Appeals of the City of White Plains within a specified time
for a special permit in accordance with the city's zoning
ordinance."
A dissenting justice stated:
i am in complete agreement with appellants' conten-
tion that if the definition of 'family' contained in the
zoning ordinance of the respondent City of White
Plains is not construed as including a 'group family' as
that term is defined in subdivision 17 of section'371
of the Social Services Law and a 'foster parent' as
those words are defined in subdivision 19 (id.), the
zoning ordinance would be void for invidious discrim-
ination.
Ile felt that simply relegating the applicant to seek a
special permit was not sufficient protection for the over-
riding state interest in providing for abandoned or neglected
children. However, he also took the position that:
I believe that in view of the elaborate and compre-
hensive provisions contained in the Social Services
Law the state has fully preempted the field, Leaving
no room (except for very limited police powers) to
the local communities to restrict the areas, within
their geographical boundaries, where group homes
may be located.
The dissenting justice would have dismissed the action
against the defendants to enjoin their use of the house in
question as a group horse.
City of White Plains v. Ferraioli, Supreme Court of New
York, Appellate Division, Second Department (intermediate
court], Decided December 18, 1972, 339 N.Y.S.2d 27