Kentucky Revised Statutes

Ky. Rev. Stat. § 100.213 (2026)

Findings necessary for proposed map amendment -- Reconsideration

✓ current as of May 2026

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(1) Before any map amendment is granted, the planning commission or the legislative body or fiscal court must find that the map amendment is in agreement with the adopted comprehensive plan, or, in the absence of such a finding, that one (1) or more of the following apply and such finding shall be recorded in the minutes and records of the planning commission or the legislative body or fiscal court: (a) That the existing zoning classification given to the property is inappropriate and that the proposed zoning classification is appropriate; (b) That there have been major changes of an economic, physical, or social nature within the area involved which were not anticipated in the adopted comprehensive plan and which have substantially altered the basic character of such area. (2) The planning commission, legislative body, or fiscal court may adopt provisions which prohibit for a period of two (2) years, the reconsideration of a denied map amendment or the consideration of a map amendment identical to a denied map amendment. Effective: July 15, 1986 History: Amended 1986 Ky. Acts ch. 141, sec. 21, effective July 15, 1986. -- Amended 1980 Ky. Acts ch. 325, sec. 1, effective July 15, 1980. -- Amended 1968 Ky. Acts ch. 198, sec. 1. -- Created 1966 Ky. Acts ch. 172, sec., 34.

Notes of Decisions

Cited in 40 cases (9 in the last 5 years), 1968–2025 · leading case: Fritz v. Lexington-Fayette Urban Cnty. Gov't, 986 S.W.2d 456 (Ky. Ct. App. 1998).

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Fritz v. Lexington-Fayette Urban Cnty. Gov't, 986 S.W.2d 456 (Ky. Ct. App. 1998). · cites it 14× “KRS 100.213 goes further than McDonald, supra , and adds that in order to get the requested zone change, the proponent must also show that the proposed zoning classification is appropriate.”

Warren Cnty. Citizens v. Bd. of Commissioners, 207 S.W.3d 7 (Ky. Ct. App. 2006). · cites it 4× “The comprehensive plan as here can include a current land-use plan or map which the legislative body can zone appropriately.”

McKinstry v. Wells, 548 S.W.2d 169 (Ky. Ct. App. 1977). · cites it 3× “The circuit court held that all parties had been denied due process because of the failure of both the Versailles-Midway-Wood-ford County Planning and Zoning Commission and the Woodford County Fiscal Court to make any findings of fact as required by KRS 100.213. The 1975…”

Bryan v. Salmon Corp., 554 S.W.2d 912 (Ky. Ct. App. 1977). · cites it 4× “s Court instructed the circuit court to direct the fiscal court to comply with one of the following alternatives: (1) To follow the recommendation of the planning and zoning commission; (2) To review the record made before the planning and zoning commission and make its own…”

21st Century Dev. Co., LLC v. Watts, 958 S.W.2d 25 (Ky. Ct. App. 1997). · cites it 4× “213 provides that before a zone change request is granted (map amendment), the planning commission or respective legislative body must find either that the proposal is in agreement with the comprehensive plan or that the existing classification is inappropriate and that the…”

Boron Oil Co. v. Cathedral Found., Inc., 434 S.W.2d 640 (Ky. Ct. App. 1968). · cites it 6× “The Boron Oil Company sought a change in the zoning map of the City of Covington pursuant to the provisions of KRS 100.213 in order to use a lot at 12th and Scott streets for the erection of a service station.”

Taylor v. Coblin, 461 S.W.2d 78 (Ky. Ct. App. 1970). · cites it 3× “” KRS 100.213 defines the conditions necessary to authorize or support a zoning-map amendment or land-use reclassification.”

Louisville & Jefferson Cnty. Plan. Comm'n v. Schmidt, 83 S.W.3d 449 (Ky. 2001). · cites it 2× “KRS 100.213. The rezoning must either be in agreement with the original comprehensive plan, or there must have been an unanticipated major change in circumstances since the adoption of the plan.”

Hines v. Pinchback-Halloran Volkswagen, Inc., 513 S.W.2d 492 (Ky. Ct. App. 1974). · cites it 4× “KRS 100.213. Appellee, Pinchback-Halloran Volkswagen, Inc.”

Hougham v. Lexington-fayette Urban Cnty., 29 S.W.3d 370 (Ky. Ct. App. 2000). · cites it 3× “2d 25 (1997), specifically dealt with this issue when it stated: KRS 100.213 provides that before a zone change request is granted (map amendment), the planning commission or respective legislative body must find either that the proposal is in agreement with the comprehensive…”

City of Louisville v. McDonald, 470 S.W.2d 173 (Ky. Ct. App. 1971). “” 1 KRS 100.213 states that before any “map amendment,” 2 is granted the planning commission or the legislative body must find that the map amendment is in agreement with the community’s comprehensive plan unless it is specifically found that one or more of the following states…”

Danville-Boyle Cnty. Plan. Comm'n v. Centre Estates, 190 S.W.3d 354 (Ky. Ct. App. 2006). · cites it 5× “KRS 100.213, quoted in full below, sets out the findings that are required before a city may make an amendment to an approved zone map: (1) Before any map amendment is granted, the planning commission or the legislative body or fiscal court must find that the map amendment is in…”

Show all 40 citing cases →

— Ky. Rev. Stat. § 100.213(1) — 8 cases

Warren Cnty. Citizens v. Bd. of Commissioners, 207 S.W.3d 7 (Ky. Ct. App. 2006). “The comprehensive plan as here can include a current land-use plan or map which the legislative body can zone appropriately.”

Hacker v. Baesler, 812 S.W.2d 706 (Ky. 1991).

Hougham v. Lexington-fayette Urban Cnty., 29 S.W.3d 370 (Ky. Ct. App. 2000). “2d 25 (1997), specifically dealt with this issue when it stated: KRS 100.213 provides that before a zone change request is granted (map amendment), the planning commission or respective legislative body must find either that the proposal is in agreement with the comprehensive…”

Hume v. Franklin Cnty. Fiscal Court, 276 S.W.3d 748 (Ky. 2009).

Raz, Inc. v. Mercer Cnty. Fiscal Court (Ky. Ct. App. 2022).

— Ky. Rev. Stat. § 100.213(1)(a) — 6 cases

Fritz v. Lexington-Fayette Urban Cnty. Gov't, 986 S.W.2d 456 (Ky. Ct. App. 1998). “KRS 100.213 goes further than McDonald, supra , and adds that in order to get the requested zone change, the proponent must also show that the proposed zoning classification is appropriate.”

21st Century Dev. Co., LLC v. Watts, 958 S.W.2d 25 (Ky. Ct. App. 1997). “213 provides that before a zone change request is granted (map amendment), the planning commission or respective legislative body must find either that the proposal is in agreement with the comprehensive plan or that the existing classification is inappropriate and that the…”

Danville-boyle Cnty. v. Centre Estates, 190 S.W.3d 354 (Ky. Ct. App. 2006).

Paris City Comm'n v. John Vance (Ky. Ct. App. 2023).

— Ky. Rev. Stat. § 100.213(1)(b) — 1 case

Paris City Comm'n v. John Vance (Ky. Ct. App. 2023).

— Ky. Rev. Stat. § 100.213(2) — 6 cases

Johnson v. Lagrew, 447 S.W.2d 98 (Ky. Ct. App. 1969).

Caller v. Ison, 508 S.W.2d 776 (Ky. Ct. App. 1974).

Wells v. Fiscal Court of Jefferson Cnty., 457 S.W.2d 498 (Ky. Ct. App. 1970).

Danville-Boyle Cnty. Plan. Comm'n v. Centre Estates, 190 S.W.3d 354 (Ky. Ct. App. 2006). “KRS 100.213, quoted in full below, sets out the findings that are required before a city may make an amendment to an approved zone map: (1) Before any map amendment is granted, the planning commission or the legislative body or fiscal court must find that the map amendment is in…”

Hume v. Franklin Cnty. Fiscal Court, 276 S.W.3d 748 (Ky. 2009).

— Ky. Rev. Stat. § 100.213(l)(a) — 4 cases

Minton v. Fiscal Court of Jefferson Cnty., 850 S.W.2d 52 (Ky. Ct. App. 1992).

Hume v. Franklin Cnty. Fiscal Court, 276 S.W.3d 748 (Ky. 2009).

— Ky. Rev. Stat. § 100.213(l)(b) — 1 case

Gramex Corp. v. Lexington-Fayette Urban Cnty. Gov't, 973 S.W.2d 75 (Ky. Ct. App. 1998).

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