The end of an era: Suburban village aversion in citizens for Mount Vernon v. city of Mount Vernon

In 1990, the Washington Legislature enacted the Growth Management Act (GMA) to counteract problems related to unmanaged population growth. The GMA fun damentally altered two traditional aspects of land use law: the disregard f or planning documents and the aversion to mixing uses within zones. Countie s and cities planning under the Act now must have comprehensive plans and z oning ordinances that are consistent with those plans. They are also encour aged 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 Su preme Court of Washington applied pre-GMA common law to decide the effect o f comprehensive plans on specific land use decisions. It held that zoning o rdinances supersede inconsistent comprehensive plans in such decisions. Thi s Note analyzes Mount Vernon and concludes that the Supreme Court of Washin gton needlessly clung to pre-GMA notions that avoid planning and mixed-use zoning in residential districts. This Note recommends that the court abando n pre-GMA case law in future land use cases and consider bifurcating the st andard of judicial review of land use cases.