I am a planner in Penna who is researching other state's procedures for validity challenges on substantive (not procedural) grounds. Penna has (I think) an unusual procedure. A landowner who is challenging a zoning ordinance is able to submit an ordinance amendment to "cure" the alleged defect in the ordinance. The governing body, or the court upon appeal, may adopt this amendment if it agrees with the challenge. Typically, the governing body denies the challenge, it is appealed, and, if the court agrees, the amendment must be adopted. Does anyone know of any other state that permits this type of landowner-initiated amendment? My understanding of other states is that a landowner may challenge an ordinance, but the governing body retains the right to amend its ordinance on its own, it is not required to accept a landowner-written amendment.