Arlin George Hatfield, III v. The Board of Supervisors of Madison County, Mississippi – zoning – Hatfield purchased a lot in Deer Haven subdivision in Madison County in 2012 and thereafter began raising. In 2013 the Homeowners Association sued him for violating the subdivision covenants, In 2015 the county cited Hatfield for raising various fowl on his property. When Hatfield failed to remove the animals, the Madison County Board of Supervisors found that he was violating zoning ordinances. Hatfield appealed by filing a bill of exceptions. The circuit court found no error and Hatfield appealed again. The Mississippi Supreme Court affirms.