## Facts

- A landowner (a shooting association) sought to rezone a 223-acre parcel in Scott County, Iowa, from Agricultural One (A-1) to Agricultural Two (A-2) to build a shooting house and target house for club use, leaving most land in agriculture.
- The parcel was surrounded by land zoned A-1, an agricultural protection district with more restrictive permitted uses than A-2.
- The county zoning and planning commission held two public hearings; the commission vote split 3–3 and forwarded the matter to the county board without an approval recommendation.
- The county planning director recommended approval.
- Neighboring landowners opposed the change, citing concerns about noise, impacts on livestock, increased activity, and fire hazards.
- The Scott County Board of Supervisors enacted an ordinance rezoning the parcel from A-1 to A-2, enabling recreational/club uses not permitted in A-1.
- Neighboring landowners sought certiorari review in district court, which invalidated the ordinance as illegal spot zoning; the shooting association appealed.

## Issues

1. Whether rezoning a 223-acre parcel from A-1 to A-2, surrounded by A-1 land, primarily to allow a private shooting facility constituted illegal spot zoning.
2. Whether the rezoning was consistent with the county’s comprehensive plan and the protective purpose of the A-1 district.
3. Whether the rezoning bore a reasonable relationship to public health, safety, and welfare, or chiefly conferred private benefit.

## Decision

- The Iowa Supreme Court affirmed the district court’s judgment invalidating the rezoning ordinance.
- The court held the ordinance constituted illegal spot zoning because it created an “island” of less restrictive zoning within a uniform agricultural protection district.
- The court found the change inconsistent with the A-1 agricultural protection purpose and unsupported by a sufficient public-welfare justification.
- The court concluded the rezoning primarily benefited the shooting association’s project rather than advancing the comprehensive plan and the public interest.

## Legal Principles

- Spot zoning occurs when a parcel is singled out for different treatment from surrounding, similarly situated land, chiefly for a particular owner’s benefit rather than pursuant to the comprehensive plan and public welfare.
- In evaluating spot zoning claims, courts consider: (1) consistency with the comprehensive plan, (2) the character of the surrounding area and existing permitted uses, and (3) whether the action is substantially related to public health, safety, and welfare versus private gain.
- Zoning ordinances are presumptively valid as legislative acts, but that presumption is overcome when the record shows an arbitrary or unreasonable departure from comprehensive planning to confer a narrow private advantage.

## Conclusion

The rezoning of the 223-acre tract from A-1 to A-2 was invalid as illegal spot zoning because it carved out a less restrictive enclave within an agricultural protection area to accommodate a private shooting club, without adequate support that the change furthered the comprehensive plan or a sufficient public-welfare purpose.


Little v. Winborn, 518 N.W.2d 384 (Iowa 1994)