Tinsley Properties, LLC et al. v. Grundy County, Tennessee

This appeal focuses on whether a Grundy County Resolution that regulates the location of quarries is, in effect, a zoning ordinance enacted in violation of Tennessee’s County Zoning Act (“the CZA”). The Plaintiffs claim the Resolution is invalid because Grundy County did not comply with the procedural requirements for passing a zoning ordinance as mandated by the CZA. The Plaintiffs further contend that the County could not utilize its police powers to regulate the location of quarries because the Resolution was preempted by state law. Grundy County argues that the Resolution was not a zoning ordinance, but rather a valid exercise of the County’s police powers. The trial court entered judgment in favor of Grundy County, and the Court of Appeals affirmed. Tinsley Props., LLC v. Grundy Cnty., No. M2022-01562-COA-R3-CV, 2024 WL 495700 (Tenn. Ct. App. Feb. 8, 2024), perm. app. granted, (Tenn. June 27, 2024). We granted permission to appeal. Based on our review of applicable law, we conclude that Grundy County enacted what amounts to a zoning ordinance without complying with the statutory requirements contained in the CZA. Therefore, we hold that the trial court erred by granting summary judgment in favor of Grundy County. Accordingly, we reverse the judgment of the Court of Appeals, vacate the trial court’s judgment, and remand the case to the trial court for further proceedings consistent with this opinion.