Question juridique clé
Whether the zoning of the parcel to a free zone constituted a material expropriation requiring compensation.
Solution extraite
No material expropriation was established because the measure was a non-zoning, and neither concrete development intentions, significant prior expenditures, nor special reliance interests justified compensation.
Motifs extraits
Non-zonings are generally non-compensable. The appellant had not manifested concrete and realizable development plans, had made no relevant expenditures, and the planning history did not create a protected expectation strong enough to replace the requirement of significant investments.