City of Virginia Beach v. Virginia Land Investment Ass'n No. 1

Different standards for determining the validity of comprehensive zoning ordinances and piecemeal downzoning ordinances have been established in our prior opinions. In Board of Supervisors v. Carper, 200 Va. 653, 107 S.E.2d 390 (1959), we considered a single zoning ordinance which amended Fairfax County’s comprehensive zoning law. The ordinance applied to the entire western two-thirds of Fairfax County and required a minimum of two acres for residential home development. If the landowner aggrieved by the ordinance was to prevail, we required that he prove that the ordinance was “clearly…