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<br />19. 89 N.C. App. 610, 366 S.E.2d 885, rev. denied, 323 N.C. 171, 373 S.E.2d 103 (1988). The
<br />fact that an adjacent 16-acre tract owned by the same person had been rezoned to a mobile home
<br />park some eleven years earlier did not change the court's conclusion that this was spot zoning.
<br />20. Mahaffey v. Forsyth County, 99 N.C. App. 676, 682, 394 S.E.2d 203 (1990), rev. denied,
<br />327 N.C. 636, 399 S.E.2d 327 (1991). But see Orange County v. Heath, 278 N.C. 688, 180
<br />S.E.2d 810 (1971), in which the court held that rezoning a 15-acre tract from a residential district
<br />to a mobile home park was not spot zoning because it adjoined a 5-acre tract already in legal use
<br />as a mobile home park.
<br />21.30 N.C. App. 611, 228 S.E.2d 750, rev. denied, 291 N.C. 178, 229 S.E.2d 692 (1976). There
<br />were two preexisting mobile home parks in the extraterritorial zoning area, both of which were
<br />zoned for mobile home use. One was three-fourths of a mile from this tract, the other two-and-
<br />one-half miles. The litigation was initiated some five-and-a-half years after the contested
<br />rezoning. The court applied a traditional laches analysis and allowed the litigation. G.S. 160A-
<br />364.1, which establishes anine-month statute of limitations for challenging rezonings, was
<br />subsequently adopted.
<br />22.47 N.C. App. 357, 267 S.E.2d 30, rev. denied, 301 N.C. 92, 273 S.E.2d 298 (1980). 23. The
<br />planning board's reasons for a favorable recommendation were "(1) Because of how long it has
<br />been there. (2) You can't tell a man that he can't grow and will have to go up U.S. 74 to expand.
<br />(3) How long they have had the land." Id. at 359, 267 S.E.2d at 32.
<br />24. 61 N.C. App. 100, 300 S.E.2d 273 (1983).
<br />25. Id. at 104, 300 S.E.2d at 275. The court concluded that the rezoning constituted improper
<br />contract zoning as well as improper spot zoning.
<br />26. 99 N.C. App. 676, 394 S.E.2d 203 (1990), rev. denied, 327 N.C. 636, 399 S.E.2d 327 (1991).
<br />27. Id. at 683, 394 S.E.2d at 207.
<br />28. 108 N.C. App. 231, 423 S.E.2d 537 (1992).
<br />29. 116 N.C. App. 168, 447 S.E.2d 438 (1994), rev. denied, 338 N.C. 524, 453 S.E.2d 179
<br />(1995).
<br />30. Id. at 175.
<br />31. However, the governing board's attempted rezoning would have made this policy, which
<br />applied to all land zoned R-A, inapplicable to this site. An argument can be made then that the
<br />rezoning is not inconsistent with the policies in the zoning ordinance. This re-emphasizes the
<br />importance of being able to point to a comprehensive plan or other planning studies, reports, and
<br />policies extrinsic to the zoning ordinance itself.
<br />32. 55 N.C. App. 107, 284 S.E.2d 742 (1981), rev, denied, 305 N.C. 299, 290 S.E.2d 702 (1982).
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