Live Oak Group purchased Tybee Island property after being told it was zoned for a single-family residence, but the property was actually zoned for a planned unit development. The City denied Live Oak’s application to amend the building standards, and Live Oak sued for inverse condemnation and related constitutional violations. The trial court granted Live Oak summary judgment on inverse condemnation while resolving the remaining claims separately. The Georgia Court of Appeals reversed in both companion appeals. It held that denial of the zoning amendment was not an inverse condemnation because the City had not taken affirmative action for a public purpose that created a nuisance or trespass and diminished the property’s utility or functionality. A zoning decision may support a constitutional takings claim in some circumstances, but that theory is distinct from inverse condemnation and could not sustain the judgment entered here. The court also declined to decide Live Oak’s federal takings claim because the trial court had not reached its merits. After reversing the inverse-condemnation ruling, it remanded that claim for consideration. The decision preserves the distinction between a regulatory or constitutional taking and an inverse condemnation based on physical or functional damage to property. Judgment was reversed in both cases, with the federal claim remanded.