City of Pharr v. Tippitt
Texas Supreme Court
616 S.W.2d 173 (1981)
Pharr (defendant) rezoned a 10.1-acre undeveloped farmland tract from single-family to multifamily residential, the tract being the closest such undeveloped land to the city center among similar farmland zoned for single-family use; the mayor testified the city needed more multifamily housing and no other suitably located or sized tract existed, and the change would increase potential structures on the tract from only 44 to 50. Tippitt (plaintiff) sued to invalidate the ordinance as unlawful "spot zoning"; the trial court upheld it, but the court of civil appeals reversed.
Whether the party seeking invalidation of a rezoning ordinance has the burden to prove that the ordinance is arbitrary or unreasonable in that it bears no substantial relationship to the health, safety, morals, or general welfare of the community.