Conn. Gen. Stat. » Title 08 — · Chapter 124 — Zoning
Connecticut General Statutes

Conn. Gen. Stat. § 8-2h (2026)

Zoning applications filed prior to change in zoning regulations not required to comply with change. Applications for building permit or certificate of occupancy filed prior to adoption of zoning regulations not required to comply with regulations

✓ current as of May 2026
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(a) An application filed with a zoning commission, planning and zoning commission, zoning board of appeals or agency exercising zoning authority of a town, city or borough which is in conformance with the applicable zoning regulations as of the time of filing shall not be required to comply with, nor shall it be disapproved for the reason that it does not comply with, any change in the zoning regulations or the boundaries of zoning districts of such town, city or borough taking effect after the filing of such application.

(b) An application for a building permit or certificate of occupancy filed with the building official of a city, town or borough prior to the adoption of zoning regulations by such city, town or borough in accordance with this chapter shall not be required to comply with, nor shall it be disapproved for the reason that it does not comply with, such zoning regulations.

(P.A. 89-311, S. 2.)

Cited. 220 C. 527; 225 C. 1.

Cited. 25 CA 199; 26 CA 212.

Subsec. (a):

Cited. 28 CA 314; Id., 379; 40 CA 501; Id., 840. States that if zoning regulations are changed after an application is filed, that application need not comply in order to be approved. 63 CA 176.

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Notes of Decisions
Cited in 17 cases (2 in the last 5 years), 1991–2025 · leading case: Protect Hamden/North Haven from Excessive Traffic & Pollution, Inc. v. Plan. & Zoning Comm'n, 600 A.2d 757 (Conn. 1991).
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Protect Hamden/North Haven from Excessive Traffic & Pollution, Inc. v. Plan. & Zoning Comm'n, 600 A.2d 757 (Conn. 1991). · cites it 10× “General Statutes § 8-2h (a) 12 controls the mootness claim in this case.”
Homart Dev. Co. v. Plan. & Zoning Comm'n, 600 A.2d 13 (Conn. App. Ct. 1991). · cites it 11× “The plaintiff argues that this (1) amounts to an unauthorized, retroactive moratorium on the consideration of PRSD zone applications, (2) is not among the criteria specified in General Statutes § 8-2 that may be considered by a zoning authority in adopting regulations and…”
Harris v. Zoning Comm'n, 788 A.2d 1239 (Conn. 2002). · cites it 4× “General Statutes § 8-2h (a). 21 Therefore, lots that are subject to the amendment *436 axe treated differently than lots that are statutorily exempt from the amendment.”
Daw v. Zoning Bd. of Appeals of Westport, 772 A.2d 755 (Conn. App. Ct. 2001). · cites it 11× “C Benson’s final claim is that General Statutes § 8-2h (a), 2 in conjunction with the 1959 variance, exempts the proposed addition from the current zoning regulations.”
Michel v. Plan. & Zoning Comm'n, 612 A.2d 778 (Conn. App. Ct. 1992). · cites it 7× “Planning & Zoning Commission, supra, the court recognized that General Statutes § 8-2h (a), which became effective on October 1,1989, legislatively overruled McCallum v.”
Cole v. Plan. & Zoning Comm'n, 671 A.2d 844 (Conn. App. Ct. 1996). · cites it 6× “which is in conformance with the applicable zoning regulations as of the time of filing shall not be required to comply with, nor shall it be disapproved for the reason that it does not comply with, any change in the zoning regulations .”
Levine v. Plan & Zoning Comm'n, 594 A.2d 9 (Conn. App. Ct. 1991). · cites it 3× “General Statutes § 8-2h, effective October 1, 1989, provides that an application that is in conformance with applicable zoning regulations at the time of its filing cannot be disapproved for its failure to comply with a subsequent change in the zoning regulations.”
Samperi v. Plan. & Zoning Comm'n, 674 A.2d 432 (Conn. App. Ct. 1996). · cites it 2× “See General Statutes § 8-2h (a). The trial court afforded the plaintiffs the practical relief of sustaining their appeal of the commission’s approval of an *845 application for a subdivision on property abutting then-own.”
McLoughlin v. Plan. & Zoning Comm'n, 200 Conn. App. 307 (Conn. App. Ct. 2020). · cites it 3× “See General Statutes § 8-2h (a). Section 8-2h (a) provides that ‘‘[a]n application filed with a zoning commission, planning and zoning commission, zoning board of appeals or agency exercising zoning authority of a town, city or borough which is in conformance with the applicable…”
R.C. Equity Grp., LLC v. Zoning Comm'n, 939 A.2d 1122 (Conn. 2008). · cites it 4× “The legislature superseded the McCallum principle with the subsequent enactment of General Statutes § 8-2h (a), which provides: "An application filed with a zoning commission, planning and zoning commission, zoning board of appeals or agency exercising zoning authority of a…”
VIP OF BERLIN, LLC v. Town of Berlin, 951 A.2d 714 (Conn. Super. Ct. 2008). · cites it 3× “89-311 of the 1989 Public Acts enacted General Statutes § 8-2h, which provides that an application that is in conformance with applicable zoning regulations as of the time of filing shall not be required to comply with nor shall it be disapproved because it does not comply with…”
Town of Branford v. Santa Barbara, 988 A.2d 209 (Conn. 2010). · cites it 2× “See General Statutes § 8-2h (a) C‘[a]n application filed with a zoning commission, planning and zoning commission, zoning board of appeals or agency exercising zoning authority of a town, city or borough which is in conformance with the applicable zoning regulations as of the…”
Show all 17 citing cases →
— Conn. Gen. Stat. § 8-2h(a) — 1 case
Jackson Hill Road Sharon CT, LLC v. Town of Sharon, 561 F. Supp. 2d 240 (D. Conn. 2008).
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