Board of Supervisors v. Snell Construction Corp.

This appeal presents our first opportunity to consider the standard to be applied in judicial review of the validity of a zoning ordinance, enacted on motion of the zoning authority, which effects a piecemeal reduction of permissible residential density (downzoning).

Under the 1964 Annandale Comprehensive Master Plan, a 26 acre tract of land lying south of State Route 236 between Backlick Road on the east and Ravensworth Road on the west in Annandale, now owned by Snell Construction Corporation and Preston Construction Corporation (landowners), was zoned for low residential density. On May 16,…