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Zoning Bulletin December 25, 2017 I Volume 11 I Issue 24 <br />where a landowner claims harm from a particular zoning classification, inverse <br />condemnation is not an available remedy unless the landowner can meet the separate <br />and distinct requirements for such a claim." <br />Case Note: <br />The City had also cross -appealed the superior court's finding that Diversified showed <br />a significant detriment. Because the appellate court affirmed the trial court's decision <br />that the denial of Diversifred's application was not arbitrary or capricious, the appel- <br />late court did not reach the City's contention on cross appeal. <br />Validity of Zoning Ordinance —City <br />ordinance imposes overlay district <br />that prohibits "mobile home parks <br />or courts" <br />Property owner seeking to construct mobile homes <br />argues that the term "mobile home parks or courts" was <br />unconstitutionally vague <br />Citation: Edwards v. City of Warner Robins, 2017 W, 4870994 (Ga. 2017) <br />GEORGIA (10/30/17)—This case addressed the issue of whether the term <br />"mobile home court or park" as used in a city's zoning ordinance was <br />"unconstitutionally vague" as applied. The case also addressed whether a <br />city's denial of a property owner's request to replace an existing mobile home <br />or construct new mobile homes violated the property owner's vested rights. <br />The Background/Facts: Since 1973, Charles Edwards ("Edwards") and <br />his wife, Carol Edwards, (collectively, the "Edwardses") had rented out a <br />mobile home on each of three lots (the "1973 lots") that Edwards owned in the <br />City of Warner Robins (the "City"). In June 1997, the Edwardses purchased <br />properties (the "1997 lots") adjoining the three 1973 lots, with all lots then <br />owned comprising seven acres with 36 lots. Each lot either had a mobile home <br />on it or was being held out for use by a mobile home. <br />At the time of the Edwardses' 1997 lots purchase, however, mobile homes <br />were prohibited on the 1973 lots and the 1997 lots under the City's 1994 Base <br />Environs Overlay District ("BEOD") Ordinance. The BEOD was an overlay <br />district that prohibited "manufactured housing" or "mobile homes" in the zon- <br />ing district where the Edwardses' owned property. The BEOD Ordinance did <br />provide exemptions for nonconforming uses. Thus, the Edwardses' original <br />three mobile homes (on the 1973 lots) had been permitted since 1994 as <br />nonconforming uses. <br />In 1997, the Edwardses requested, and the City granted, a rezoning of the <br />© 2017 Thomson Reuters 7 <br />