Big time Utah Court of Appeals decision in her favor:
 
http://courtlink.utcourts.gov/opinions/appopin/hugoe.htm
 
Their property was legal when they bought it, then zoning changed, they
get to keep using it despite the zoning change, something called "zoning
estoppel."  And even these guys were given notice and a chance to comply.
 
From the Utah constitution:  Some are long shots, but...
 
"      Article I, Section 24.   [Uniform operation of laws.]
      All laws of a general nature shall have uniform operation."
 
This is good.  If she can show others were notified and given a chance
to rectify zoning violations, she's got them here.
 
"Article XII, Section 20.   [Free market system as state policy --
Restraint of trade and monopolies prohibited.]
 
It is the policy of the state of Utah that a free market system shall
govern trade and commerce in this state to promote the dispersion of
economic and political power and the general welfare of all the people.
Each contract, combination in the form of trust or otherwise, or conspiracy
in restraint of trade or commerce is prohibited.  Except as otherwise
provided by statute, it is also prohibited for any person to monopolize,
attempt to monopolize, or combine or conspire with any other person or
persons to monopolize any part of trade or commerce.  "
 
If her shelter can be called a trade (it is a corporation) and some kind of
conspiracy can be shown, such as how no notice given, etc., looks fishy,
it's unconstitutional.
 
 "Article I, Section 10.   [Trial by jury.]
In capital cases the right of trial by jury shall remain inviolate.  In
capital cases the jury shall consist of twelve persons, and in all other
felony cases, the jury shall consist of no fewer than eight persons.  In
other cases, the Legislature shall establish the number of jurors by
statute, but in no event shall a jury consist of fewer than four persons.
In criminal cases the verdict shall be unanimous.  In civil cases
three-fourths of the jurors may find a verdict.  A jury in civil cases
shall be waived unless demanded.  "
 
She may be able to demand a jury if this action is considered as against
her.
 
From regular Utah law:
 
"Utah Code Title 19 Chapter 6
     10-9-402.   Preparation and adoption.
     (1) The planning commission shall prepare and recommend to the
legislative body a proposed zoning ordinance, including both the full
text of the zoning ordinance and maps, that represents the commission's
recommendations for zoning all or any part of the area within the
municipality.
     (2) (a) The legislative body shall hold a public hearing on the
proposed zoning ordinance recommended to it by the planning commission.
     (b) The legislative body shall provide reasonable notice of the
public hearing at least 14 days before the date of the hearing.  If a
municipality mails notice of a proposed zoning change to property owners
within that municipality within a specified distance of the property on
which the zoning change is being proposed, it shall also mail equivalent
notice to property owners of an adjacent municipality within the same
distance of the property on which the zoning change is being proposed.
     (3) After the public hearing, the legislative body may:
     (a) adopt the zoning ordinance as proposed;
     (b) amend the zoning ordinance and adopt or reject the zoning
         ordinance as amended; or
     (c) reject the ordinance."
 
Were these procedures followed?  Why didn't she know about this?  And
check out the appeals process.  Is she being given the chance below?
 
"10-9-704.   Appeals.
     (1) (a) (i) The applicant or any other person or entity adversely
affected by a decision administering or interpreting a zoning ordinance
may appeal that decision applying the zoning ordinance by alleging that
there is error in any order, requirement, decision, or determination
made by an official in the administration or interpretation of the
zoning ordinance.
     (ii) The legislative body shall enact an ordinance establishing a
reasonable time for appeal to the board of adjustment of decisions
administering or interpreting a zoning ordinance.
     (b) Any officer, department, board, or bureau of a municipality
affected by the grant or refusal of a building permit or by any other
decisions of the administrative officer in the administration or
interpretation of the zoning ordinance may appeal any decision to the
board of adjustment.
     (2) The board of adjustment shall hear and decide appeals from
planning commission decisions regarding conditional use permits unless
the zoning ordinance designates the legislative body or another body to
hear conditional use permit appeals.
     (3) The person or entity making the appeal has the burden of
proving that an error has been made.
     (4) (a) Only decisions applying the zoning ordinance may be
appealed to the board of adjustment.
     (b) A person may not appeal, and the board of adjustment may not
consider, any zoning ordinance amendments.
     (5) Appeals may not be used to waive or modify the terms or
requirements of the zoning ordinance."
 
And the one below shows some intent of state law on the whole zoning thing:
 
"17-27-701.   Board of adjustment -- Appointment -- Term -- Vacancy.
     (1) In order to provide for just and fair treatment in the
administration of local zoning ordinances, and to ensure that substantial
justice is done, each county adopting a zoning ordinance shall appoint a
board of adjustment to exercise the powers and duties provided in this
part."
 
Again, if she can show that her treatment wasn't fair (such as others
having been given notice), then they are in violation of state law and
maybe even the constitution.  If she wants to research, I suggest
www.findlaw.com.
[Posted in FML issue 3537]