City’s denial of zoning permit for free-standing bell tower on Church property violated Telecommunications Act of 1996.


CELLULAR SOUTH REAL ESTATE, INC. d/b/a CELLULAR SOUTH v. CITY OF GERMANTOWN, (UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE, June 22, 2015).
 
The issues before the Court were as follows: (a) whether the decision to deny Cellular South's Application was not supported by "substantial evidence contained in a written record," in accordance with 47 U.S.C. § 332(c)(7)(B)(iii), and (b) whether the Board's denial of Cellular South's application effectively prohibited the provision of personal wireless services in violation of 47 U.S.C. § 332(c)(7)(B)(i)(II).
 
The Court held that although the residents provided their opinion as to the potential devaluation of their property based on perceived negative impact on aesthetics, they did not support their testimony with substantial evidence.   The Court stated that the residents’ opinions were not based on objective evidence and instead amount to asserting: "not in my backyard."  Accordingly, the Court found that the City's reasons for denial concerning aesthetics and property values were not based on substantial evidence in the record.  The Court also found that the City’s denial had "the effect of prohibiting the provision of personal wireless services" in violation of 47 U.S.C. § 332(c)(7)(B)(i)(II).