Municipal Zoning; Mandatory Referendum For Zoning Amendments; Lawful Delegation of Legislative Power; Due Process; City of Eastlake v. Forest City Enterprises, Inc.

IN City of Eastlake v. Forest City Enterprises, Inc.," the United States Supreme Court held that a mandatory referendum on all zoning changes did not violate the Due Process Clause of the United States Constitution. The Court decided that such referenda are not delegations of legislative power, but exercises of the people's reserved power. Therefore, they need not be accompanied by discernible standards as with delegations of power to administrative agencies.