Corrigan v. City of Scottsdale
In Corrigan v. City of Scottsdale, 149 Ariz. 553, 720 P.2d 528 (App. 1985), vacated on other grounds, 149 Ariz. 538, 720 P.2d 513 (1986), a city zoning ordinance defined a perimeter within which no development could occur.
The ordinance divided the plaintiff's contiguous property into two separate zones.
All land within the "no development" area was to be used solely for conservation of open space and legally secured for such conservation by easement or dedication.
Further, in Corrigan the city had recognized that compensation was required and had awarded property owners "density credits" based on the amount of each owner's land that fell within the conservation zone. The court determined that the density credits there did not constitute just compensation. See id.