## Facts

- The City of Springfield, a charter city, adopted a charter provision allowing a zoning-change protest petition by 10% of affected landowners and requiring a three-quarters city-council vote to approve the change after a valid protest.
- Missouri statute § 89.060 permits a protest petition only if signed by 30% of affected landowners and, if valid, requires a two-thirds vote of the municipal legislative body for the zoning change to take effect.
- Dorothy and Genevieve Haydon sought rezoning to operate a bed and breakfast in a single-family residential area; a protest petition was filed by more than 10% but less than 30% of affected landowners.
- Applying the charter provision, the city council treated the protest as valid and required a three-quarters vote; the rezoning failed to reach that threshold and was declared defeated.
- Lon and Debora Goff sought rezoning to allow a small motel instead of previously approved uses; a protest petition met the charter’s 10% threshold but not the statute’s 30% threshold.
- The city council voted 5–3 in favor of the Goff rezoning, but it did not reach the charter’s three-quarters requirement after a valid protest and was declared defeated.
- The City filed a declaratory-judgment action seeking a ruling that its charter provision was valid and not in conflict with § 89.060.
- The trial court held the charter provision conflicted with § 89.060 and was invalid; the City appealed.

## Issues

1. Whether § 89.060 violates the Missouri Constitution by impermissibly limiting or denying charter-city powers.
2. Whether Springfield’s charter provision is valid under the Missouri Constitution when it conflicts with § 89.060’s protest-petition and supermajority-vote requirements.

## Decision

- The Supreme Court of Missouri (en banc) affirmed the trial court.
- The court held § 89.060 is constitutional.
- The court held Springfield’s charter provision is invalid to the extent it conflicts with § 89.060.
- The court concluded the charter could not alter the statutory thresholds for (i) the percentage of landowners needed to file a valid protest petition and (ii) the supermajority vote required after a valid protest.

## Legal Principles

- Charter cities may exercise municipal powers only to the extent those powers are not limited or denied by statute under the Missouri Constitution.
- The General Assembly may enact uniform, general laws governing municipal zoning procedure, including protest-petition mechanics and voting thresholds.
- When a valid state zoning statute prescribes a specific protest-and-vote scheme, a conflicting charter provision is unenforceable, even if it is more restrictive than the statute.
- A direct conflict exists where local law changes the statutory triggers for a protest petition and the resulting supermajority vote requirement for zoning changes.

## Conclusion

The Missouri Supreme Court upheld the state’s zoning protest statute and ruled that Springfield’s charter provision could not substitute a lower protest threshold and higher supermajority requirement in place of the statutory scheme, rendering the charter provision invalid where it conflicted with state law.


City of Springfield v. Goff, 918 S.W.2d 786 (Mo. 1996)