In Golden v. Planning Bd. of Ramapo (30 NY2d 359, 285 N.E.2d 291, 334 N.Y.S.2d 138 [1972]), landowners challenged as unconstitutional a municipal ordinance that required the landowners to obtain special permits before applying for approval from the town planning board to subdivide their properties for residential development. These special permits were required to prevent urban sprawl, and the permit requirements were designed so that virtually no permits would be issued. Even though the landowners had never sought to obtain the special permits, the Court of Appeals held that there was a justiciable controversy, as the ordinance had the effect of destroying the marketability of the landowners' properties for residential purposes. (Golden, 30 NY2d at 364-68.)