Udell v. Haas

Udell's (plaintiff) eastern and western parcels had both been zoned for business use for over a decade, consistent with the Village's (defendant) longstanding zoning map and ordinances; the same evening Udell's associate submitted development plans for a bowling alley and supermarket on the western parcel, the planning board recommended rezoning both parcels to residential, citing traffic concerns, and the Village adopted that recommendation a month later. The trial court found the western parcel's rezoning unconstitutionally confiscatory but upheld the eastern parcel's rezoning as consistent with the neighborhood.

Whether, under zoning law, rezoning must be performed in accordance with a comprehensive plan.