Michigan Compiled Laws

Mich. Comp. Laws § 125.3202 (2026)

Zoning ordinance; determination by local legislative body; amendments or supplements; notice of proposed rezoning.

✓ current as of July 2026
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MICHIGAN ZONING ENABLING ACT


Act 110 of 2006


125.3202 Zoning ordinance; determination by local legislative body; amendments or supplements; notice of proposed rezoning.

Sec. 202.

    (1) The legislative body of a local unit of government may provide by ordinance for the manner in which the regulations and boundaries of districts or zones shall be determined and enforced or amended or supplemented. Amendments or supplements to the zoning ordinance shall be adopted in the same manner as provided under this act for the adoption of the original ordinance.

    (2) Except as provided in subsection (3), the zoning commission shall give a notice of a proposed rezoning in the same manner as required under section 103.

    (3) For any group of adjacent properties numbering 11 or more that is proposed for rezoning, the requirements of section 103(2) and the requirement of section 103(4)(b) that street addresses be listed do not apply to that group of adjacent properties.

    (4) An amendment to a zoning ordinance by a city or village is subject to a protest petition under section 403.

    (5) An amendment to conform a provision of the zoning ordinance to the decree of a court of competent jurisdiction as to any specific lands may be adopted by the legislative body and the notice of the adopted amendment published without referring the amendment to any other board or agency provided for under this act.

History: 2006, Act 110, Eff. July 1, 2006 ;-- Am. 2008, Act 12, Imd. Eff. Feb. 29, 2008

Notes of Decisions
Cited in 16 cases (10 in the last 5 years), 2008–2025 · leading case: Whitman v. Galien Twp., 808 N.W.2d 9 (Mich. Ct. App. 2010).
Whitman v. Galien Twp., 808 N.W.2d 9 (Mich. Ct. App. 2010). “[MCL 125.3202(1).] *680 The MZEA also provides that a local zoning ordinance may include provisions for special-use permits within a zoning district as follows: The legislative body may provide in a zoning ordinance for special land uses in a zoning district.”
Tuscola Wind III, LLC v. Almer Charter Twp., 327 F. Supp. 3d 1028 (E.D. Mich. 2018). “§ 125.3202(1), because it was passed by resolution and not via the legislative procedures set forth in the ZEA.”
Lisa Montrief v. MacOn Twp. Bd. of Trs. (Mich. Ct. App. 2025). · cites it 6× “3201(1); MCL 125.3202. The MZEA also provides for the rezoning of land through ordinances.”
Karen Connell v. Lima Twp. (Mich. Ct. App. 2021). · cites it 2× “” MCL 125.3202(2). It is undisputed that the Planning Commission is a “zoning commission” under the MZEA.”
Eureka Bldg. Inc v. City of Troy (E.D. Mich. 2020). · cites it 2× “” Mich. Comp. Laws § 125.3202 (1). And the Troy Zoning Ordinance applies the same standard to approve “traditional” rezoning applications as for “conditional” applications: “a rezoning may only be approved upon a finding and determination” if the same five relevant factors are…”
Fulton v. Lilly, Twp. of (W.D. Mich. 2025). · cites it 2× “But the state legislature has empowered local municipalities to establish zoning regulations through the Zoning Enabling Act, Mich. Comp. Laws § 125.3202 (1). See Whitman v.”
David Hoffman v. Porter Twp. (Mich. Ct. App. 2015). · cites it 2× “3201; MCL 125.3202. On remand, the circuit court should explore the propriety of the 2011 ZBA decision, in light of the deputy zoning administrator’s determination that the island had never been zoned, and the apparent absence of any record of any action by the township board,…”
Saugatuck Dunes Coastal All. v. Saugatuck Twp. (Mich. 2022). “3201; MCL 125.3202. Further, the powers 14 See Black’s Law Dictionary (11th ed) (defining “party” as “[s]omeone who takes part in a transaction .”
Saugatuck Dunes Coastal All. v. Saugatuck Twp. (Mich. 2022). “3201; MCL 125.3202. Further, the powers 14 See Black’s Law Dictionary (11th ed) (defining “party” as “[s]omeone who takes part in a transaction .”
Save Our Downtown v. City of Traverse City (Mich. Ct. App. 2022). “An initiative that purports to enact or amend a zoning ordinance is invalid unless it complied with the procedural requirements found in the Michigan zoning enabling act (MZEA), MCL 125.”
Ronald a Jostock v. Mayfield Twp. (Mich. Ct. App. 2023). “’ ” Whitman, 288 Mich App at 679 , quoting MCL 125.3202(1). In this case, the process that produced the rezoning agreement is not at issue.”
Ronald a Jostock v. Mayfield Twp. (Mich. Ct. App. 2023). “’ ” Whitman, 288 Mich App at 679 , quoting MCL 125.3202(1). In this case, the process that produced the rezoning agreement is not at issue.”
— Mich. Comp. Laws § 125.3202(1) — 6 cases
Whitman v. Galien Twp., 808 N.W.2d 9 (Mich. Ct. App. 2010). “[MCL 125.3202(1).] *680 The MZEA also provides that a local zoning ordinance may include provisions for special-use permits within a zoning district as follows: The legislative body may provide in a zoning ordinance for special land uses in a zoning district.”
Tuscola Wind III, LLC v. Almer Charter Twp., 327 F. Supp. 3d 1028 (E.D. Mich. 2018). “§ 125.3202(1), because it was passed by resolution and not via the legislative procedures set forth in the ZEA.”
Save Our Downtown v. City of Traverse City (Mich. Ct. App. 2022). “An initiative that purports to enact or amend a zoning ordinance is invalid unless it complied with the procedural requirements found in the Michigan zoning enabling act (MZEA), MCL 125.”
Ronald a Jostock v. Mayfield Twp. (Mich. Ct. App. 2023). “’ ” Whitman, 288 Mich App at 679 , quoting MCL 125.3202(1). In this case, the process that produced the rezoning agreement is not at issue.”
Ronald a Jostock v. Mayfield Twp. (Mich. Ct. App. 2023). “’ ” Whitman, 288 Mich App at 679 , quoting MCL 125.3202(1). In this case, the process that produced the rezoning agreement is not at issue.”
— Mich. Comp. Laws § 125.3202(2) — 2 cases
Karen Connell v. Lima Twp. (Mich. Ct. App. 2021). “” MCL 125.3202(2). It is undisputed that the Planning Commission is a “zoning commission” under the MZEA.”
Lisa Montrief v. MacOn Twp. Bd. of Trs. (Mich. Ct. App. 2025). “3201(1); MCL 125.3202. The MZEA also provides for the rezoning of land through ordinances.”
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