Hughes v. Town of Oak Island

STEELMAN, Judge,

concurring in part and dissenting in part.

I concur in parts A and B of the majority’s opinion, but I respectfully dissent from parts C and D.

Part C of the majority opinion affirmed the ruling of the trial court which held that respondent’s annexation was an impermissible “shoestring” annexation. Only one reported appellate case has found an annexation to be invalid on this basis. In Amick v. Town of Stallings, 95 N.C. App. 64, 382 S.E.2d 221 (1989), the Town used a strip of land 7,411 feet long and varying in width from 50 to 200 feet to meet the one-eighth contiguous boundary requirement under N.C. Gen. Stat. § 160A-36(b)(2) (2001). The trial court concluded that this portion of the proposed annexation had “ ‘no relationship to any urban or municipal purpose’ ” and remanded the ordinance for amendment. Id. at 68, 382 S.E.2d at 224. This Court affirmed the trial court’s order remanding for amendment and held that even though the Town literally complied with the statutory requirements, the annexation subverted the underlying purpose of the statute to ensure sound urban development. Id. at 71, 382 S.E.2d at 225-26.

In this case, the configuration of the annexation area does not rise to the level of flouting the intent of the statute as was found in Amick. Unlike the narrow “shoestring” corridor in Amick which had no relation to commercial activity, the proposed annexation here followed a commercial corridor along a major roadway. Such annexation does not contravene the statute’s policy of ensuring sound urban development. The configuration of the annexation area should not have been a basis for invalidating the annexation in the instant case. It is only in such unusual cases as Amick that the court should invalidate an annexation ordinance which complies with the requirements of the statute.

As to part D of the majority opinion, upon a finding that an annexation ordinance is invalid, the trial court may either remand the ordinance to the municipality for amendment or declare the ordinance null and void, if it cannot be corrected by amendment. N.C. Gen. Stat. § 160A-38(g) (2001). In this case, defendant presented a revised plan *187for annexation drawn by a registered land surveyor which clearly showed that even with the exclusion of the Big Toy Storage tract, the annexation area could be amended to comply with all provisions of N.C. Gen. Stat. Chapter 160A. I would remand the ordinance to defendant for amendment rather than declaring it null and void.