Washington Law Review


Ronda Larson


In 1990, the Washington Legislature enacted the Growth Management Act (GMA) to counteract problems related to unmanaged population growth. The GMA fundamentally altered two traditional aspects of land use law: the disregard for planning documents and the aversion to mixing uses within zones. Counties and cities planning under the Act now must have comprehensive plans and zoning ordinances that are consistent with those plans. They are also encouraged to use innovative zoning tools such as mixed-use housing developments. In the 1997 case Citizens for Mount Vernon v. City of Mount Vernon, the Supreme Court of Washington applied pre-GMA common law to decide the effect of comprehensive plans on specific land use decisions. It held that zoning ordinances supersede inconsistent comprehensive plans in such decisions. This Note analyzes Mount Vernon and concludes that the Supreme Court of Washington needlessly clung to pre-GMA notions that avoid planning and mixed-use zoning in residential districts. This Note recommends that the court abandon pre-GMA case law in future land use cases and consider bifurcating the standard ofjudicial review of land use cases.

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