IN 1971 FOREST CITY ENTERPRISES applied to the Planning Commission of Eastlake, Ohio, to rezone its property, an eight-acre parcel of land, from industrial to multi-family high-rise use. After the application was filed, initiative petitions were circulated proposing the adoption of an amendment to the Eastlake city charter. The proposed amendment provided for mandatory voter approval' of any ordinance changing the city's existing comprehensive zoning plan. An amendment to this effect was adopted in November, 1971.
Bond, Jane E.
"Mandatory Referendum for Zoning Amendments; Unlawful Delegation of Legislative Power; Denial of Due Process; Forest City Enterprises, Inc. v. Eastlake,"
Akron Law Review: Vol. 9
, Article 9.
Available at: http://ideaexchange.uakron.edu/akronlawreview/vol9/iss1/9