Garrett v. Roanoke City Council — Planning Commission Had Authority to Continue Rezoning Hearing; No Re-Advertising Required
The Virginia Court of Appeals affirmed dismissal of a challenge to a Roanoke rezoning, holding that planning commissions have implied Dillon Rule authority to continue a rezoning hearing from one regularly scheduled meeting to the next without fresh advertising—the original notice covers the continued session, a post-hearing statutory amendment to Code § 15.2-2204 does not apply retroactively, and non-substantive amendments to the application do not independently trigger re-advertising.