Fritz v. City of Kingman

The City of Kingman (defendant) adopted a 1992 general zoning plan broadly permitting one to four residences per acre in the area including Kiersten Fritz's (plaintiff) land, though her parcel was specifically zoned R-R allowing only one dwelling per acre at the time. In 1997, the City granted Fritz's request to reclassify her land as R-1-8, permitting up to four dwellings per acre while remaining consistent with the 1992 general plan; a citizens' group then petitioned to refer that reclassification decision to the voters via referendum. Fritz sued to reject the referendum petitions, arguing the reclassification was a non-referable administrative act; the trial court disagreed, finding it legislative, and Fritz appealed, arguing the 1992 general plan itself was the true legislative act subject to referendum, not the later reclassification.