Two Trees Farm, Inc. v. Planning Board of Town of Southampton
This case involves a CPLR article 78 proceeding initiated by petitioners to challenge a determination made by the Planning Board of the Town of Southampton. The Planning Board had conditionally approved the petitioners' application for preliminary subdivision approval after amending their draft environmental impact statement (DEIS), citing concerns about the subdivision's consistency with a voluntary agricultural conservation program. The Supreme Court, Suffolk County, initially granted the petition, annulled the Planning Board's determinations, remitted the matter, and directed the Board to approve the application. However, the appellate court found the Planning Board's decision to amend the DEIS arbitrary and capricious, affirming the annulment of the determinations and the need for further environmental review based on the original DEIS. Crucially, the appellate court modified the judgment by removing the directive for the Planning Board to approve the subdivision, emphasizing that the court should not substitute its judgment for that of the Planning Board on substantive State Environmental Quality Review Act (SEQRA) matters.