Wood v. City of Madison

The Woods (plaintiffs) sought to subdivide and rezone land from agricultural to commercial use, but Madison (defendant) denied their extraterritorial plat application under its subdivision ordinance. The Woods argued Madison had improperly used subdivision-approval authority to regulate land use — a domain, they contended, reserved exclusively for zoning law. The circuit court upheld Madison's denial, and the court of appeals certified the question to the state supreme court.

Whether, under Wisconsin subdivision law, a municipality may reject a preliminary plat under its extraterritorial jurisdictional authority based on a subdivision ordinance that considers the land's use.