In International Outdoor, Inc v City of Livonia, the Michigan Court of Appeals upheld a zoning ordinance provision banning new billboards. The court held that the ordinance does not "zone out" a legal business in violation of state law, because it did not prevent the advertising companies from soliciting and serving clients within the city, but instead only prohibited a single form of advertising. The plaintiff also failed to establish a need for billboards within the city, relying in part on evidence that surrounding communities permitted billboards. The court stated that, in order to establish a cause of action under the Michigan Zoning Enabling Act, the challenger would have to demonstrate "public need for new billboards rather than a demand for those billboards by advertisers."

While this decision is a significant victory for municipalities, it does not provide blanket authority to prohibit billboards or other uses through a zoning ordinance. Instead, the legality of these ordinances depends on the circumstances in the community. Municipalities must cautiously evaluate the relative demand and existing supply of the use.

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