Property II, Pages 844–849

Village of Euclid v. Ambler Realty Co.

Supreme Court of the United States, 1926

Facts:

Plaintiff owns 68 acres under various zoning restrictions. It had intended to use it for industrial purposes, but the zoning restrictions prevented much of it from being used as such. Part was restricted to only single-family residences and duplexes, part could also include apartments, and the rest could have any type of building built. The land has a value of $10,000 per acre for industrial development purposes but only $2,500 per acre for residential, and the first two-hundred feet from the main street has a similarly disparate $150 to $50 valuation per front foot for unrestricted versus residential uses. Plaintiff filed suit to have the ordinance voided as in violation of section 1 of the Fourteenth Amendment.

Procedural History:

District court held the ordinance to be unconstitutional and void.

Issue:

Does the zoning ordinance violate section 1 of the Fourteenth Amendment's right to property?

Reasoning:

  • Plaintiff argues that the zoning is void because it is too broad. However, a law may include a reasonable extra margin in order to ensure effective enforcement. This law is reasonable and not merely arbitrary.

  • The village is allowed to exclude businesses from residential areas. If it could not, nearby Cleveland's industry would soon consume the village of Euclid. If a city can regulate industries while not regulating residences, it can regulate where they are located if it would harm the residents. Industrial development can easily cause harm through increased traffic, risk of fire, noise, etc.

  • Where an injunction is sought for the mere existence of an ordinance, the court will not look at the minor effects not contributing to the injury complained of. Plaintiff is seeking an injunction against the enforcement of any restrictions of the ordinance because it is preventing it from reselling its land for industrial use. However, no provision of the ordinance affects the marketability of land alone, the ordinance in its general scope is valid.

Rule:

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[I]t must be said before the ordinance can be declared unconstitutional that such provisions are clearly arbitrary and unreasonable, having no substantial relation to the public health, safety, morals, or general welfare.

Holding:

No, the zoning ordinance is valid. Reversed.

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