Campion v. Board of Aldermen of New Haven

New Haven's 1925 enabling ordinance authorized planned development districts letting landowners simultaneously seek rezoning and approval for a specific development plan; landowners the DelMonacos sought to consolidate several parcels under this mechanism, and both the planning commission and the Board of Aldermen (defendant) approved the plan as consistent with the town's comprehensive plan and beneficial to the community. Neighbor Campion (plaintiff) challenged the approval, arguing the town lacked authority to enact the planned-development-district ordinance in the first place; the trial court upheld the board's decision, and Campion appealed.

Whether a municipality's enabling ordinance, which authorizes rezoning through traditional floating zones, provides sufficient authority for the municipality to also approve planned development districts that similarly alter existing zoning boundaries.