Town of Hollywood v. Floyd

The Town of Hollywood filed suit against William Floyd, Troy Readen, and Edward McCracken (collectively, the developers) seeking a declaration that the developers could not subdivide their property without approval from the Town’s Planning Commission and an injunction prohibiting subdivision of the property until such approval was obtained. The developers filed counterclaims under 42 U.S.C. 1983 alleging equal protection and due process violations as well as various state law claims. The circuit court granted summary judgment in favor of the Town on its claims for equitable and declaratory relief, and also granted the Town’s motion for a directed verdict on the developers’ state law claims. The jury returned a verdict in favor of the Town on the developers’ due process claim, but awarded the developers $450,000 in actual damages on their equal protection claim. Both parties appealed. The Town argued that the circuit court erred in denying its motions for a directed verdict and judgment notwithstanding the verdict (JNOV) on the developers’ equal protection claim, and in granting the developers’ motion for attorney’s fees and costs. The developers argued the circuit court erred in granting summary judgment in favor of the Town on its claims for equitable and declaratory relief. Upon review, the Supreme Court affirmed in part and reversed in part. The Court concluded that the circuit court properly granted summary judgment in favor of the Town on its claims for declaratory and injunctive relief., but erred in denying the Town’s motions for a directed verdict and JNOV because the developers failed to show the Planning Commission treated them differently than other similarly situated developers in the subdivision application process.

Town of Hollywood v. Floyd