B.J. Alan Co. v. Congress Township Board of Zoning Appeals

{¶ 1} We address today the “comprehensive plan” requirement of R.C. 519.02. R.C. 519.02 allows township trustees to create, by resolution, zoning regulations to cover the unincorporated portions of townships. The statute requires such zoning resolutions to be “in accordance with a comprehensive plan.” This case presents the question of whether the comprehensive plan required by the statute must be a plan developed by the township itself or whether the township may rely on a comprehensive plan created at the county level. We hold that a countywide comprehensive plan can fulfill the…