In Foothill Communities v. County of Orange (4th Dist. 2014), 2014 WL 108975, the County of Orange approved a 153-unit senior housing development on 7 acres in the middle of a neighborhood zoned residential single-family by creating a new ‘senior residential housing land use’ zoning district and then rezoning the subject property to that designation. The legal issue was whether this constituted illegal “spot zoning”.