City of Miami Beach v. Stearns

It is true, as pointed out in the opinion of Associate Justice Murphree, that “accessory uses” are defined in the zoning ordinance of Miami Beach as “uses customarily incident to the principal uses as permitted, but not including any commercial activity.” It must be observed, however, that this definition is found in Section 1 of the ordinance where the phrase “accessory uses” as well as many other phrases used in the zoning ordinance is defined. The only purpose of Section 1 is to define the general phrases used in the ordinance itself.

The use of the property on which the subject hotel is…