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£1kin.~ It was subsequently considered in Zopfl v. district and the particular characteristics of the area City o/ Wflmington,~s but it was not until Blades v. being rczoned, or {3) by the classification and use of Raleigh~ that om- appellate courts actually found nearby land. The North Carolina Supreme Court "spotzoning*J tohave occurred. Itwas that case that disagreed. gave us the North Carolina definition of this prat- Justice Meyer described the determination of flee: whether there was a sufficient reasonable basis to support "spot zoning" as a "balancing of interests" A zoning ordinance, or amendment, which involving such factors as the size of the t~aet being singles out and teclassilies a relatively small rezuncd, the compatibility ol the action with an t tact owned by a single person and surrounded existing comprehensive plan, the benefits and harm by a much larger area unifarrni¥ zoned~ so as to impose upon the small tract Heater rescale- resulting from the zoning action[both for the owner tions than those imposed upon the larger area, of the rezoned property and for the neighbors and or so as to relieve the small tract from restrio- sm-rounding community}, and the relationship be- tions to which the test of the area is subiected, tween the uses envisioned under the new zoning and is called "spot zoning." It is b~yond the au- the uses currently present in adjacent tracts. In rhorit¥ o{ the municipality, in the absence of a clear showing of a reasonable basis far such other words~ he called for a factual analysis rather distinction? . than a mete verbal interpretation as a basis for determining whether illegal *'spot zoning'* has nc- The legal basis for this rule has nowhere been cuffed. stated, but it appears to be rooted in the North Proceedingwiththiskindofanalysis, thecouxt Carolina Constitution's provisions that prohibit the found that there was general support for the rezon- granting of "exclusive privileges" {Article I, Section lng from all neighbors but the plaintiff, that it was 32), the creation of monopolies l/~rricle I, Section clear that the proposed operations would be a valu- $4}, or the denial of equal protection under the law able and necessary service for the agricultural com- [Axticl¢I~Section 19}alsoUrdtedStatesConstimtion, munity surrounding the tract, and that there was a Fourteenth Amendment]. strong similarity between the uses permitted under Since the Blades decision [which involved the proposed rezoning and the uses alreadlt present reznning approximarely 5 acres}, the rule has been in surrounding areas. In these circumstances the applied in a succession of court of appeals deci- court had little difficulty in finding a '~reasonahle sinus--each with raged toqoite large"spots': Starts basis" for the "spot zoning" amendment. v. Swalm {4 acres},:~ Lathan v. Board o[ Commis. sinners [11.41~Z acres), ~2 Godpey v. Union County Holding Number 3: Contract Zoning Board o~ Comrrd~sioners [17.45 acres},:~ AJderman v. Chatham Coum), {14.2 acres],TM and the Chris. The court moved next to the question of moo ease. But this was the first occasion since whether the rezoning constituted illegal "contract Blades in which the supreme court had had an op- zoning," as the court of appeals had held. portuniW to amplify the rationale to be applied in Before describing the court's treatment of this determining "spot zoning." issue, some history is once again appropriate, In In this opinion the court stressed that not all other states "contract zoning" traditionall)~ has zoning amendments meeting the "spot zoning" involvedasituationinwhichanapplieantfor rezon- criteria were illegal. Focusing on the second sen- lng has attempted to defuse opposition by agreeing tence of tho definition quoted abovet it said that to enter into a written contract with the local SOy- some apparent nspot zoning'* was legal [if it had a emment, specifying thatifit wouldrezonehisorher reasonable basi$}~ whereas other "spot zoning" was property to a certain classification, the applicant not {if it had no such basis}. The court of appeals had would use that property only in a specified manner found that Guilford County had failed to'show a [rather than preserving the right to use it for any or reasonable basis, citing three principal reasons: the all pm.poses listed in the ordinance}. Sometimes the rezoning was not called for'{1} by any change o[ owner agreed to strengthen this commitment by conditions on the land, [2} by the character of the recording a deed restriction on the property. In