Overview
The city of Clayton solicited redevelopment plans for one block of Forsyth Boulevard. Centene Plaza Redevelopment Corporation submitted the plan approved by Clayton, which included condemnation authority. When Centene failed to reach agreement with all the property owners to acquire the properties, it filed this condemnation action. Mint Properties and several other defendants resisted the condemnation on the basis that the property was not blighted, as defined by section 353.020, RSMo 2000. The trial court found in favor of Centene. Because the finding of blight was not supported by substantial evidence, the judgment is reversed.
Development of the plan
Centene purchased property located at 7700 Forsyth and 21 Hanley with the intent to expand its current office and parking space. Centene also sought to purchase a garage owned by the city adjacent *433to Centene’s current office building. During discussions about purchasing the garage, Centene discovered that the city was seeking redevelopment of the area.
The city subsequently issued a general request seeking proposals from developers to redevelop the entire block of Forsyth bordered by South Bemiston Avenue, Han-ley Road, and Carondelet Avenue. Cen-tene submitted the only response to the request for proposals. Centene proposed a three-phase project that included formation of a redevelopment corporation, tax abatement, and the power of eminent domain.
The city reviewed Centene’s response and then commissioned Peckham, Guyton, Albers, & Viets (“PGAV”) to conduct an analysis of the area to determine whether it qualified as a blighted area. PGAV’s analysis ultimately concluded that the property qualified as a blighted area.
The city subsequently passed an ordinance declaring the area to be blighted and approving Centene’s plan. The area included defendants’ properties. After approval of the plan, Centene sought to acquire the affected properties. When these efforts failed, condemnation actions were filed.
Standard of review
This Court examines the record to determine whether there is substantial evidence to support the legislative decision. Binger v. City of Independence, 588 S.W.2d 481, 486 (Mo. banc 1979).
Blight requires a showing of “social liability”
Section 353.020 sets forth the definition of “blighted area.” A blighted area consists of those portions of the city that “by reason of age, obsolescence, inadequate or outmoded design or physical deterioration have become economic and social liabilities, and that such conditions are conducive to ill health, transmission of disease, crime or inability to pay reasonable taxes-” (Emphasis added.) Centene concedes that the determination of blight must include findings that the area in question is both an economic liability and a social liability.
Although the term “social liability” is not specifically defined by statute or in case law, the historical context suggests the definition of “social liability” focuses upon the health, safety, and welfare of the public. In that regard, it has been noted that the transformation of this country from primarily agricultural to a predominantly industrial society resulted in significant growth in the cities. Tax Increment Financing Com’n of Kansas City v. J.E. Dunn Const. Co., Inc., 781 S.W.2d 70, 78 (Mo. banc 1989). One result of this growth was blighted areas, which constituted a “menace injurious to the public health, safety, morals and welfare” of the residents. Id. The blighted areas also presented economic concerns. Id. The need to eliminate these conditions as a “breeding ground for juvenile delinquency, infant mortality, crime and disease” prompted a movement toward redevelopment. Id.
The evidence of social liability was insufficient2
Based on the foregoing definition of “social liability,” the evidence was insuffi-*434dent. In particular, the evidence before the city concerning fire, police, and emergency services reports did not support a conclusion of social liability. Michael Schoedel, the city manager, testified that he requested information from the Clayton fire and police departments regarding the calls in the area. A memorandum from Mark Thorp, the fire chief, indicated that from 2001 to 2006, there were no fire calls and no emergency services calls at all for most of the properties in the redevelopment area, and collectively, there were only four fire calls and two emergency responses for eight properties in the area over the course of five years.
Tom Burn, the chief of police, also submitted a memorandum to Schoedel, indicating the number of police calls to the properties in the redevelopment area dating back to 1999. There were a total of 143 calls for five properties over approximately seven years, but this was less than half the number of calls for a single property located across the street during that time frame.
Although Schoedel expressed some potential concerns regarding safety, crime, fire hazards, and vandalism due to vacancies in the area, the information he received from the fire and police departments did not validate these concerns. In addition, there was no evidence presented regarding any public health concerns resulting from the condition of the area.
According to Schoedel, the PGAV blighting study commissioned by the city was a critical component in the city’s determination of blight. However, while the PGAV study did conclude that the area was an economic liability because of the age, obsolescence, inadequate or outmoded design, and physical deterioration of some of the properties, it did not make any conclusions regarding the social liability of the area. Moreover, the PGAV study did not find that any of these conditions were injurious to the public health or safety. In fact, John Brancaglione, PGAVs employee, testified that the factors existent in the area did not constitute a social liability in the way he “understood that to be applicable to these situations.” Instead, Branca-glione testified that the area was a social liability only to the extent that it constituted an economic liability because of its inability to pay reasonable taxes. Nevertheless, Centene argues that the blighting study prepared by PGAV was not the only factor in the city’s determination of blight. However, as noted, Schoedel specifically testified that the PGAV study was a critical component in the determination of blight.
Centene also claims that the determination of blight was supported by substantial evidence by citing the increase in jobs the redevelopment would provide and the “vibrant,” pedestrian-friendly atmosphere that would result from the redevelopment. However, this evidence focuses only upon the prospective benefits of redevelopment — not the current state of the properties themselves. The city’s ultimate goals for the area cannot serve as probative evidence of social liability in fight of the lack of evidence concerning the public health, safety, and welfare in the record. Furthermore, if evidence to support a find*435ing of economic liability could also constitute evidence to support a finding of social liability, the plain language of section 353.020 would be defeated.
Finally, while under section 353.020(1), an “area” may include buildings that are not themselves blighted, but which are deemed necessary for the redevelopment, there is a lack of evidence of social liability as to any portion of the area sought to be condemned. The area, therefore, failed to meet the statutory definition of “blighted area.”3
Conclusion
The judgment is reversed.
WOLFF, C.J., TEITELMAN, LIMBAUGH and RUSSELL, JJ., concur. STITH, J., concurs in separate opinion filed. LYNCH, Sp.J., concurs in opinion of STITH, J. WHITE, J., dissents in separate opinion filed. PRICE, J., not participating.. The Court of Appeals, Eastern District, transferred this case to this Court by per curiam opinion. Mo. Const, article V, section 10. Parts of that opinion are incorporated without further attribution.
. After Centene filed actions for condemnation of the properties, the legislature enacted section 523.261, RSMo Supp.2006. The statute states that with regard to condemnation actions, "any legislative determination that an area is blighted, substandard, or unsanitary shall not be arbitrary or capricious or induced by fraud, collusion, or bad faith and *434shall be supported by substantial evidence.” Prior to section 523.261, the standard of review of the legislative determination was that it must not be arbitrary or induced by fraud, collusion or bad faith. Crestwood Commons Redevelopment Corp. v. 66 Drive-In, 812 S.W.2d 903, 910 (Mo.App.1991). If the action of the legislative body was "reasonably doubtful or even fairly debatable,” the court could not substitute its judgment for that of the legislative body. It is not necessary to determine if section 523.261 applies retroactively because Clayton’s determination of blight failed to meet either standard.
. Article I, section 28 of the Missouri Constitution prohibits the taking of private property for uses that are not public and ensures judicial review of whether the use is public without regard to any legislative declaration that such use is public. These requirements prevent a condemning authority from forcing the transfer of private property from its owner primarily for benefit of another private party. The Court takes no position on whether this development project complies with these constitutional requirements. See State ex rel. Broadway-Washington Associates, Ltd. v. Manners, 186 S.W.3d 272, 274, n. 2 (Mo. banc 2006).