Village of Euclid, Ohio ET AL. v. Ambler Realty Company 272 U.S.

365 (1926) US Supreme Court Parties: Plaintiff: Village of Euclid, Ohio ET AL. Defendant: Ambler Realty Company

Facts: Appeal from a decree of the US District Court enjoining the Village and its Building Inspector from enforcing a zoning ordinance. The suit was brought by an owner of unimproved land within the corporate limits of the village, who sought the relief upon the ground that, because of the building restrictions imposed, the ordinance operated to reduce the normal value of the property, and to deprive the owner of liberty and property without due process of law. A previous ruling by the US District Court declared null and void and enforcement enjoined of Ordinance No. 2812, enacted by the municipal council of the village of Euclid, November 13, 1922, and amended by Ordinances Nos. 3367 and 3368, enacted June 11, 1923, the more commonly referred to as zoning ordinances. Thus leading to the appeal of the District Court decision by the Village of Euclid to the U.S. Supreme Court. Legal Issue: Does the Village of Euclid have the power, through zoning ordinances, forbid the erection of a building of a particular kind or for a particular use? In that preventing the use of the property held by Ambler Realty by these enacted ordnances, that the Village of Euclid prevented the due process of law, and reduced the normal value of the property. Holding: In an opinion by Justice Sutherland, supported by Justices Taft, Holmes, Brandieis, Sanford, and Stone, dissented by Justices VanDevanter, McReynolds, and Butler the Supreme Court held that the ordinances, the zoning ordinances in question, in its general scope and dominant features, so far as its provisions constantly executed, is a valid exercise of authority, leaving other provisions to be dealt with as cases arise directly involving them. Thus overturning the lower courts ruling in the favor of Ambler Realty. Rational: The relief sought here is of the same character, namely, an injunction against the enforcement of any of the restrictions, limitations or conditions of the ordinance. And the centerpiece of the complaint is that a portion of the land of the appellee cannot be sold for certain enumerated uses because of the general and broad restraints of the ordinance. What would be the effect of a restraint imposed by one or more of the innumerable provisions of the ordinance upon the value or marketability of the lands is neither disclosed by the bill nor by the evidence, and we are afforded no basis, apart from mere speculation, upon which to rest a conclusion that it or they would have any appreciable effect upon those matters. And just with speculation alone no definitive answer could come about that because of these ordinances that any kind of reduction of the normal value of the property would be present because of the prevention of the building of a particular type of structure or a particular type of use to the land. Critical Analysis: This case takes into consideration the ever-converserial subject of zoning. At the time of hearing of this case zoning had only been in use for approximately the past 25 years, leaving only a small number of communities with zoning ordinances and many parts of the country without zoning ordinances. But with the influx of people going into urban areas, many urban communities and their surrounding communities established zoning ordinances as a way to structure the makeup of the communities. But the questions raised by this case is can a town impose restrictions on to put into laymens terms the what goes where, industry vs. residential, what property can be used for, heavy vs. light industry, as well as types of structures, high-rises vs. single family

homes. The court seems to arguer that municipalities can use zoning power to structure the form of their town, as long as they are consistent with the use of zoning ordinances, and are within the ideals of constitutional principals, especially with those laid out in the 5 th and 14th Amendments. Though the court shy away from making guidelines or determining rules as to how these problems of zoning should be approached, beyond the case in question. Rather it states that it should look at cases of this sort individually by looking at the application and extension of constitutional principles to particular cases as they arise, leaving open further case examinations as they arrise.