United States Second Circuit
Holt v. Town of Stonington, 12-4878
In this diversity suit seeking equitable relief to prevent defendant from denying plaintiff her ability to build on a lot of land that she owns, the district court's award of an injunction to plaintiff based on a claim of municipal estoppel is vacated and remanded with instructions to dismiss the complaint, where: 1) under Connecticut law, a plaintiff must first exhaust available and adequate administrative remedies before she may receive judicial relief in a zoning dispute; and 2) plaintiff failed to exhaust her administrative remedies, and so the district court lacked subject matter jurisdiction.
Appellate Information
- Decided 08/29/2014
- Published 08/29/2014
Judges
- Newman, Hall, Livingston
Court
- United States Second Circuit