Roundstone Development, LLC v. City of Natchez, 105 So. 3d 317

Roundstone sought to develop Audubon Terrace in Natchez on land with O-L and R-l zoning; plan required OZR before urban subdivision.
Planning Commission denied the site plan for failure to rezone; Mayor and Board denied Roundstone’s rezoning request.
Circuit Court and Court of Appeals affirmed; the Supreme Court granted certiorari to review both the site-plan denial and the rezoning denial.
Three pre-purchase letters misrepresented the land as zoned R-l, later shown to be false statements about zoning status.
Site-plan and subdivision applications were initially approved by staff but ultimately denied by the Planning Commission pending rezoning and traffic-study completion.
Public hearing before the Board disclosed environmental, traffic, and neighborhood-concern issues; the Board denied rezoning unanimously.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the City’s interpretation of the O-L to R-l rezoning requirement was reasonable	Roundstone asserts site plan approval is ministerial since uses are permitted in O-L.	City interprets O-L as requiring reclassification before subdivision to fit the general plan and prevent improper development.	Not manifestly unreasonable; denial upheld.
Whether the City’s denial of rezoning was arbitrary, capricious, discriminatory, illegal, or without substantial basis	Roundstone contends neighborhood change and public need justify rezoning; also alleges animus concerns.	Board acted with substantial evidence and exercised discretion based on concerns and public input.	Not arbitrary, capricious, discriminatory, illegal, or without substantial basis.

Hall v. City of Ridgeland, 37 So.3d 25 (Miss.2010) (great weight given to local construction of zoning ordinances unless manifestly unreasonable)
Town of Florence v. Sea Lands, Ltd., 759 So.2d 1221 (Miss.2000) (landowners rely on zoning plans; changes require careful consideration)
Thomas v. Bd. of Supervisors of Panola County, 45 So.3d 1173 (Miss.2010) (zoning decisions reviewed for arbitrary, capricious, discriminatory actions or lack of substantial basis)
Vineyard Investments, LLC v. City of Madison, 999 So.2d 438 (Miss.Ct.App.2009) (site-plan approvals can be ministerial; building-permit analogies used)
Hillside Terrace, L.P. v. City of Gulfport, 18 So.3d 339 (Miss.Ct.App.2009) (distinguishes discretionary vs ministerial site-plan decisions)
Old Canton Hills Homeowners Association v. Mayor and City Council of the City of Jackson, 749 So.2d 54 (Miss.1999) (planned-unit developments and their restrictions; zoning vs development approvals)
Berry v. Embrey, 238 Miss. 819, 120 So.2d 165 (Miss.1960) (building permits and zoning regulations are distinct; conforming use may not be denied)