On February 27, 1998, the Supreme Court of Virginia rendered its decision in Town of Madison v. Ford. The court invalidated a town zoning ordinance which had been enacted in 1972. This extreme result was due to an insufficiency in the town council's minutes at the meeting when the ordinance in question was enacted. The minutes did not state the names of all the members present nor how they voted. The court, therefore, found that the ordinance was enacted in derogation of the provisions of article VII, section 7 of the Constitution of Virginia ("section 7").
Mark J. Yeager,
Annual Survey of Virginia Law: Constitutional Law,
U. Rich. L. Rev.
Available at: https://scholarship.richmond.edu/lawreview/vol32/iss4/4