mere inconvenience standard (Rhode Island) · Go Syfert
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mere inconvenience standard in Rhode Island

13 Rhode Island opinions name it 2 courts 1989–2011 0 in the last five years

The cases below were cited by Rhode Island courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
DiDonato v. Zoning Bd. of Review of Town of Johnstongreen
ri · 1968 · cited in 3 Rhode Island opinions naming this issue, 1991–2011
2 sentences

2011Directly on point is DiDonato v. Zoning Bd. of Review of Town of Johnston , 104 RI 158 , 242 A.2d 416 (1968).

2008Id. at 420.

23
Bernuth v. Zoning Board of Reviewgreen
ri · 2001 · cited in 2 Rhode Island opinions naming this issue, 2007–2009
2 sentences

2009See Hugas Corp. v. Veader , 456 A.2d 765 , 770 (R.I. 1983) ("trial justice erred in upholding the board's utilization of the variance standard and in not remanding the case for reconsideration under the special-exception standard"); see also Von Bernuth , 770 A.2d at 402 (trial justice erred in upholding zoning board's decision where the decision included no discussion of the hardship or reasonable alternative factors under § 42-24-41(d)(2) and where "there is no evidence that the zoning board considered or applied the statutory requirement, given that the statute is not acknowledged in the zo

2007The case at bar is distinguished from von Bernuth v. Zoning Bd. of Review , 770 A.2d 396 , 402 (R.I. 2001), which Appellant cites for the contention that the court cannot affirm a zoning board's decision where the court "[could not] determine what evidence that was presented to the zoning board persuaded it that the requirement of § 42-24-41(d)(2) [the mere inconvenience standard] had been met." Here, it is apparent that the difference between the square footage requirement and Appellant's a lot size — 1600 square feet — would create more than a mere inconvenience if the Applicant's petition w

12
Felicio v. Fleurygreen
ri · 1989 · cited in 2 Rhode Island opinions naming this issue, 1991–1999
2 sentences

1999Id. ("the fact that land located within a residential zone could not be used for a dwelling if setback requirements were enforced has been held to satisfy more than a mere inconvenience standard") (citing Gara Realty, Inc. v. Zoning Bd. of Review of S. Kingstown , 523 A.2d 855 , 858 (R.I. 1987)).

1991Felicio, 557 A.2d at 482 ; Gara Realty, Inc., 523 A.2d at 858 .

12
Hugas Corp. v. Veadergreen
ri · 1983 · cited in 1 Rhode Island opinions naming this issue, 2009–2009
1 sentence

2009See Hugas Corp. v. Veader , 456 A.2d 765 , 770 (R.I. 1983) ("trial justice erred in upholding the board's utilization of the variance standard and in not remanding the case for reconsideration under the special-exception standard"); see also Von Bernuth , 770 A.2d at 402 (trial justice erred in upholding zoning board's decision where the decision included no discussion of the hardship or reasonable alternative factors under § 42-24-41(d)(2) and where "there is no evidence that the zoning board considered or applied the statutory requirement, given that the statute is not acknowledged in the zo

11
Lischio v. Zoning Board of Review of North Kingstowngreen
ri · 2003 · cited in 1 Rhode Island opinions naming this issue, 2007–2007
1 sentence

2007Appellants have produced evidence that their application for dimensional relief from Ordinance § 4.4(c)(8) "far exceed[s] the more than a mere inconvenience standard of proof because without dimensional relief [Appellants] would be left with no other reasonable alternative to enjoy any legally permitted beneficial use of their property." Lischio , 818 A.2d at 293 (emphasis in original).

11
Destefano v. Zoning Board of Reviewgreen
ri · 1979 · cited in 1 Rhode Island opinions naming this issue, 2004–2004
1 sentence

2004See DeStefano v. Zoning Board of Review of Warwick, 122 R.I. at 246 , 405 at 1170; Gara Realty, Inc., supra. ANALYSIS I.

11
Viti v. Zoning Board of Review of Providencegreen
ri · 1960 · cited in 1 Rhode Island opinions naming this issue, 1997–1997
2 sentences

1997See Viti v. Zoning Board of Review of the City of Providence , 92 R.I. 59 , 166 A.2d 211 (1960). 6 A review of the record indicates that the Board did not apply the Viti standard to the variance application now at issue.

1997See Viti v. Zoning Board of Review of the City of Providence , 92 R.I. 59 , 166 A.2d 211 (1960). 6 A review of the record indicates that the Board did not apply the Viti standard to the variance application now at issue.

11
Gartsu v. Zoning Bd. of Review of City of Woonsocketgreen
ri · 1968 · cited in 1 Rhode Island opinions naming this issue, 1996–1996
1 sentence

1996Gartsu v. Zoning Board of Review, 104 R.I. at 720-21, 248 A.2d at 598.

11
Brum v. Conleygreen
ri · 1990 · cited in 1 Rhode Island opinions naming this issue, 1993–1993
1 sentence

1993See also, Brum v. Conley, supra, at p. 1336.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Rhode Island. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Gara Realty, Inc. v. Zoning Board of Review green
ri · 1987
2 sentences

1999Id. ("the fact that land located within a residential zone could not be used for a dwelling if setback requirements were enforced has been held to satisfy more than a mere inconvenience standard") (citing Gara Realty, Inc. v. Zoning Bd. of Review of S. Kingstown , 523 A.2d 855 , 858 (R.I. 1987)).

1991Felicio, 557 A.2d at 482 ; Gara Realty, Inc., 523 A.2d at 858 .

31989–1999
Travers v. Zoning Bd. of Review of Town of Bristol green
ri · 1967
2 sentences

2004Though neither of these opinions uses the language "objectively unreasonable," they do exemplify the principal stated in Travers that the mere inconvenience test "must be applied reasonably and realistically." Travers, 101 R.I. at 514 , 225 A.2d at 224 .

2004Though neither of these opinions uses the language "objectively unreasonable," they do exemplify the principal stated in Travers that the mere inconvenience test "must be applied reasonably and realistically." Travers, 101 R.I. at 514 , 225 A.2d at 224 .

12004–2004
Lincoln Plastic Products Co. v. Zoning Board of Review green
ri · 1968
2 sentences

1991See, e.g., DiDonato, 104 R.I. 158 , 242 A.2d 416 (applicant sought a variance to construct a larger home due to increase in family size); Apostolou, 120 R.I. 501 , 388 A.2d 821 (mere economic impracticality was mere inconvenience thus insufficient to satisfy Viti standard); Lincoln Plastic Products Co. v. Zoning Board of Review, 104 R.I. 111 , 242 A.2d 301 (1968) (denying relief where applicants merely established their personal preference for the proposed structure).

1991See, e.g., DiDonato, 104 R.I. 158 , 242 A.2d 416 (applicant sought a variance to construct a larger home due to increase in family size); Apostolou, 120 R.I. 501 , 388 A.2d 821 (mere economic impracticality was mere inconvenience thus insufficient to satisfy Viti standard); Lincoln Plastic Products Co. v. Zoning Board of Review, 104 R.I. 111 , 242 A.2d 301 (1968) (denying relief where applicants merely established their personal preference for the proposed structure).

11991–1991
Apostolou v. Genovesi green
ri · 1978
2 sentences

1991See, e.g., DiDonato, 104 R.I. 158 , 242 A.2d 416 (applicant sought a variance to construct a larger home due to increase in family size); Apostolou, 120 R.I. 501 , 388 A.2d 821 (mere economic impracticality was mere inconvenience thus insufficient to satisfy Viti standard); Lincoln Plastic Products Co. v. Zoning Board of Review, 104 R.I. 111 , 242 A.2d 301 (1968) (denying relief where applicants merely established their personal preference for the proposed structure).

1991See, e.g., DiDonato, 104 R.I. 158 , 242 A.2d 416 (applicant sought a variance to construct a larger home due to increase in family size); Apostolou, 120 R.I. 501 , 388 A.2d 821 (mere economic impracticality was mere inconvenience thus insufficient to satisfy Viti standard); Lincoln Plastic Products Co. v. Zoning Board of Review, 104 R.I. 111 , 242 A.2d 301 (1968) (denying relief where applicants merely established their personal preference for the proposed structure).

11991–1991

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