Zehring V. City Of Bellevue

The issue in this case is whether a city planning commissioner's participation in design review hearings for a proposed office building violated the appearance of fairness doctrine when the commissioner purchased shares in the proponent corporation shortly after approval of the proposed design. The trial court found no violation of the appearance of fairness doctrine and granted partial summary judgment on that issue. The Court of Appeals, Division One, found an appearance of fairness violation and, in an unpublished opinion, reversed without prejudice to further proceedings in which the planning commissioner did not participate. The Court of Appeals affirmed on all other issues. Zehring v. Bellevue, 30 Wash. App. 1017 (1981). For the reasons set forth below, we affirm the Court of Appeals.