Lawrence v. Zoning Bd. of Appeals of Town of North Branford
In Lawrence v. Zoning Bd. of Appeals of Town of North Branford, 158 Conn. 509, 264 A.2d 552 (Conn. 1969), the court defined "incidental use" as a use which is not the primary use of the property but rather one which is subordinate and minor in significance as compared to the primary use.
The court also said that, to constitute an incidental use, the use must be attendant or concomitant to the primary use.
The court suggested that the following factors be considered in determining whether a use is incidental:
(1) the size of the lot in question;
(2) the nature of the primary use;
(3) the use made of adjacent lots by neighbors;
(4) the economic structure of the area.