Crestar Bank v. Martin

The question for decision in this case involving mobile homes is whether a family subdivision which is exempt from compliance with a subdivision ordinance is nevertheless subject to the land-use controls of a zoning ordinance.

At the time of the proceeding below, Section 16-2 of the Montgomery County subdivision ordinance1 defined a subdivision as “the division of a parcel of land into three (3) or more lots or parcels, any of which is less than five (5) acres each, ... for the *234purpose of transfer of ownership or building development,” Section 16-16 (a) provided that no person shall subdivide…