Pleasant Prairie v. Kenosha - 75 Wis. 2d 322, 249 N.W.2d 581 (1977)

Rule:

In determining the validity of annexations it is committed to the doctrine which has come to be known as the "rule of reason." The rule of reason, which has as its essential purpose the ascertainment whether the power delegated to the cities and villages has been abused in a given case, is stated in the following terms: Under this rule, (1) exclusions and irregularities in boundary lines must not be the result of arbitrariness, (2) some reasonable present or demonstrable future need for the annexed property must be shown, and (3) no other factors must exist which would constitute an abuse of discretion.

Facts:

Appellee city annexed certain lands in the town. The annexation was commenced at the behest of two property owners who filed a petition with the city to annex the lands, and who also sought to rezone most of the proposed annexation for industrial use. After the city approved the annexation petition, the town filed a complaint for declaratory judgment. The town sought a declaration that the annexation was invalid because it purportedly violated the rule of reason, which was used to test the validity of municipal annexations. After a trial, the circuit court upheld that validity of the annexation. The town sought review of the court’s decision. 

Issue:

Was the city’s annexation of land in the town invalid? 

Answer:

No.

Conclusion:

In affirming the judgment, the court held that the town did not sustain its burden of proving that no reasonable need for the annexation existed. The court found that the town's statement that the sole purpose behind the annexation was to obtain a change in zoning was misleading and, further found that a purpose to develop one's land was legitimate for purposes of annexation. The court concluded that the city demonstrated that there existed a reasonable need for land with potential for industrial development.