The Washington (state) Supreme Court, in Sleasman v. City of Lacey (No. 77590-7, Feb. 8, 2007), decided what it means to have a developed parcel. Actually, the court determined what the terms "undeveloped" and "partially developed" mean within the context of a local ordinance that regulates tree removal on such property. The opinion is a good primer on what it means to own "developed" vs "undeveloped" property, even though it is Washington law-specific, since it discusses decisions from other jurisdictions. Bottom line, according to the court, is that development takes place when the owner makes raw land suitable for residential or commercial use. Best line in the opinion is the last, however:
Lacey claims attorney fees under RCW 4.84.370 as a prevailing party. But it isn't.
If only all court opinions were that direct.