## Facts

- A 1.18-acre tract near Rochester’s downtown was split-zoned: two-thirds R-2 (low-density multifamily) and one-third R-1 (single-family).
- Surrounding uses were mixed, including single-family homes, low-density multifamily dwellings, a 24-unit apartment building, a 35-unit condominium, and nearby institutional property.
- The A.C. Gooding Trust agreed to sell the tract to developer Rodney Younge contingent on rezoning to R-4 (high-density residential) to build a six-story, 49-unit condominium apartment building.
- City planning staff recommended tabling the request while considering changes to the land-use plan, which called for low-density residential use on the tract.
- The planning commission recommended denial as inconsistent with the land-use plan.
- After hearings, the City Council rezoned the tract from R-1/R-2 to R-4 without issuing formal written findings; meeting minutes reflected council views about housing needs, site suitability, and feasibility of lower-density development.
- Neighborhood groups and nearby homeowners sued for declaratory and injunctive relief, alleging the rezoning was quasi-judicial without required findings, arbitrary and capricious, and impermissible spot zoning.
- The district court upheld the ordinance; plaintiffs appealed.

## Issues

1. Whether rezoning a single tract is a quasi-judicial act requiring written findings supported by substantial evidence, or a legislative act entitled to a presumption of validity.
2. Whether the rezoning was arbitrary and capricious because it conflicted with the land-use plan and was allegedly unrelated to public health, safety, morals, or general welfare.
3. Whether the rezoning constituted invalid spot zoning by creating a high-density classification primarily benefiting a private developer and harming neighboring owners.

## Decision

- The Minnesota Supreme Court affirmed and upheld the rezoning ordinance.
- The court held that adoption or amendment of a zoning ordinance, even for a single tract, is a legislative act in Minnesota.
- Applying deferential review, the court concluded the ordinance had a rational basis related to public welfare and was not arbitrary or capricious.
- The court rejected the spot-zoning claim, finding the area’s mixed character and the lack of proof of concrete harm or isolated inconsistency.

## Legal Principles

- Municipal enactment or amendment of zoning ordinances is a legislative function, including single-parcel rezoning.
- Legislative zoning decisions carry a presumption of validity; challengers bear the burden to show the ordinance is arbitrary, capricious, or lacks any rational relation to public health, safety, morals, or general welfare.
- A land-use plan is a policy guide rather than a binding constraint; inconsistency with a plan or planning commission recommendations does not by itself invalidate a rezoning.
- Spot zoning is not established merely by rezoning a small tract; challengers must show substantial inconsistency with surrounding uses and evidence that the change primarily serves a private benefit with tangible adverse impacts on neighbors.

## Conclusion

The court sustained Rochester’s single-tract rezoning as a valid legislative act, holding that rational-basis deference applied, plan inconsistency did not alone show arbitrariness, and the challengers failed to prove invalid spot zoning or concrete harm.


State v. City of Rochester, 268 N.W.2d 885 (Minn. 1978)