State v. City of Rochester

Rodney Younge contracted to buy a 1.18-acre parcel near downtown Rochester to build an apartment building, contingent on the city rezoning it from single-family and low-density residential to high-density residential; the parcel bordered two existing high-density apartment buildings on one side and single-family and low-density homes on the other. Though the planning department recommended tabling the request and the planning commission recommended denying it as inconsistent with the city's land-use plan, the city council approved the rezoning after a hearing, without written findings, though its meeting minutes reflected that the council found the site well suited for an apartment building serving downtown housing needs and unlikely to be developed any other way given its neighbors; the council then amended its land-use plan to match. The Rochester Association of Neighborhoods and nearby homeowners challenged the rezoning as an invalid quasi-judicial act, or alternatively as arbitrary and capricious legislative action inconsistent with the land-use plan and unrelated to public welfare, and as unlawful spot zoning; the trial court upheld the rezoning, and the association appealed.