49. Substantial relationship.
    a. "The great weight of authority convinces us that these sections [allowing only residential buildings & sheds], as applied to the property involved in this case [church], bear no substantial relationship to the promotion of the health, safety, morals, convenience, property, or general welfare of the city of Reno, or of its residential district, and that they constitute an invasion of the property rights of petitioner corporation." [and violation of fed and state constitutions - due process; at 246]
Bishop of Reno v. Hill, 59 Nev. 231, 239, 90 P.2d 217 (1939). No. 1.
    b. "Unless we can say that the ordinance, as it affects petitioner's property, discloses an unreasonable or arbitrary exercise of power by the zoning authorities and has no substantial relation to the public health, safety, morals or general welfare, it is neither the duty nor the province of this court to interfere with the discretion invested in these authorities."
State v. Coleman, 67 Nev. 636, 641, 224 P.2d 309 (1950). No. 2.
    c. "The oft repeated, although ill defined, limitation upon the exercise of the zoning power, requires that zoning ordinances be enacted for the health, safety, morals or general welfare of the community. (citation omitted) Such ordinances must bear a substantial relationship to those police power purposes. (citation omitted) And if the ordinance does, in its application to specific properties, impose an 'unnecessary hardship,' it cannot be termed a reasonable or constitutional exercise of the police power. To preserve the validity of the zoning ordinance in its application to the community in general, the use permit and variance provisions of the ordinance function as an 'escape valve,' so that when regulations which apply to all are unnecessarily burdensome to a few because of certain unique circumstances, a means of relief from the mandate is provided."
Coronet Homes, Inc. v. McKenzie, 84 Nev. 250, 256, 439 P.2d 219 (1968). No. 10.
    d. "The Kohler court [Town of Vienna Council v. Kohler, 244 S.E.2d 542, 548 (1978)] concluded that 'a denial of a rezoning request will not be sustained if under all the facts of the particular case, the denial is unreasonable, or is discriminatory, or is without substantial relationship to the public health, safety, morals and general welfare.'"
Nova Horizon v. City Council, Reno, 105 Nev. 92, 95, 769 P.2d 721 (1989). No. 36.