English v. Augusta Township
Michigan Court of Appeals
514 N.W.2d 172 (1994)
English (plaintiff) sought to rezone his 49-acre agricultural/residential parcel to manufactured housing park (MHP) after Augusta Township (defendant) denied his petition, even though numerous developers had inquired about building manufactured housing in the township and English's site had adequate water, sewer, and road access. The township's only MHP-zoned area, an 80-acre parcel largely owned by the township supervisor with no development plans, sat far from utilities near a toxic waste site and a federal prison, and a former township official testified the site was deliberately chosen because officials believed it would never actually be developed, despite Board pressure to keep manufactured housing out of the township entirely.
Whether, if a zoning ordinance completely excludes a use that is both needed and appropriate for that area, the ordinance is exclusionary zoning and unconstitutional.