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''Village of Euclid v. Ambler Realty Co.'', 272 U.S. 365 (1926), more commonly ''Euclid v. Ambler'', was a
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
landmark case Landmark court decisions, in present-day common law legal systems, establish precedents that determine a significant new legal principle or concept, or otherwise substantially affect the interpretation of existing law. "Leading case" is commonly u ...
argued in 1926. It was the first significant case regarding the relatively new practice of
zoning Zoning is a method of urban planning in which a municipality or other tier of government divides land into areas called zones, each of which has a set of regulations for new development that differs from other zones. Zones may be defined for a s ...
. The Supreme Court's finding that local ordinance zoning was a valid exercise of the police power bolstered
zoning in the United States Zoning in the United States includes various land use laws falling under the police power rights of state governments and local governments to exercise authority over privately owned real property. Zoning laws in major cities originated with the ...
and influenced other countries.


Facts

Ambler Realty owned of land in the village of
Euclid, Ohio Euclid is a city in Cuyahoga County, Ohio, United States. It is an inner ring suburb of Cleveland. As of the 2020 census, the city had a total population of 49,692. History The City of Euclid was originally a part of Euclid Township, first ma ...
, a suburb of Cleveland. The village, in an attempt to prevent industrial Cleveland from growing into and subsuming Euclid and prevent the growth of industry which might change the character of the village, developed a zoning ordinance based upon six classes of use, three classes of height and four classes of area. The property in question was divided into three use classes, as well as various height and area classes, thereby hindering Ambler Realty from developing the land for industry. Ambler Realty sued the village, arguing that the zoning ordinance had substantially reduced the value of the land by limiting its use, amounting to a deprivation of Ambler's liberty and property without
due process Due process of law is application by state of all legal rules and principles pertaining to the case so all legal rights that are owed to the person are respected. Due process balances the power of law of the land and protects the individual per ...
.


Judgment


Lower court

In the lower court, the village moved to dismiss the complaint entirely, arguing that Ambler Realty had no right to sue in the first place without taking the issue before the Euclid Zoning Board, as required by the zoning ordinance. Euclid was basing this argument on a legal doctrine which has come to be known as the exhaustion of administrative remedies. The court denied this motion. Finding that the zoning ordinance did in fact constitute a taking by Euclid of Ambler's property, the court stated that the ordinance was unconstitutional. The ordinance defined the use and size of buildings permissible in each district. Ambler Realty's land spanned multiple districts, and the company was therefore significantly restricted in the types of buildings it could construct on the land. Thus there was no reason for the company to abide by the ordinance's requirement. Euclid's motion was denied and the lower court decided in favor of Ambler Realty. Prominent lawyer
Newton D. Baker Newton Diehl Baker Jr. (December 3, 1871 – December 25, 1937) was an American lawyer, Georgist,Noble, Ransom E. "Henry George and the Progressive Movement." The American Journal of Economics and Sociology, vol. 8, no. 3, 1949, pp. 259–269. ...
argued the case for Ambler Realty and James Metzenbaum represented Euclid.


Supreme Court

The Supreme Court agreed with the lower court's denial of the dismissal motion, but overturned the outcome of the case and sided with the Village of Euclid. The Court held that the zoning ordinance was not an unreasonable extension of the village's police power and did not have the character of arbitrary fiat, and thus it was not unconstitutional. Further, the Court found that Ambler Realty had offered no evidence that the ordinance had any effect on the value of the property in question, but based their assertions of depreciation on speculation only. The court ruled that speculation was not a valid basis for a claim of takings. Ambler Realty had argued their case on the basis of the 14th Amendment's
due process Due process of law is application by state of all legal rules and principles pertaining to the case so all legal rights that are owed to the person are respected. Due process balances the power of law of the land and protects the individual per ...
clause. The Court noted that the challenger in a due process case would have to show that the law in question is discriminatory and has no rational basis. The Court found that Euclid's zoning ordinance in fact did have a rational basis. Planner and lawyer Alfred Bettman, supported by the
Ohio Planning Conference The Ohio Planning Conference (OPC) is an association of citizens and planners that promotes city and regional planning in the state of Ohio. OPC is a chapter of the American Planning Association (APA) and is APA's second-oldest chapter. In 2010 ...
(now APA-Ohio, a chapter of the American Planning Association), submitted a friend of the court brief on behalf of Euclid, arguing that zoning is a form of nuisance control and therefore a reasonable police power measure. In short the court ruled that zoning ordinances, regulations and laws must find their justification in some aspect of police power and asserted for the public welfare. Benefit for the public welfare must be determined in connection with the circumstances, the conditions and the locality of the case.


Significance


Zoning precedent

At the time of ''Euclid'', zoning was a relatively new concept, and indeed there had been rumblings that it was an unreasonable intrusion into private property rights for a government to restrict how an owner might use property. The court, in holding that there was valid government interest in maintaining the character of a neighborhood and in regulating where certain land uses should occur, allowed for the subsequent explosion in zoning ordinances across the country. The court has never heard a case seeking to overturn ''Euclid''. Today most local governments in the United States have zoning ordinances. The city of
Houston, Texas Houston (; ) is the most populous city in Texas, the most populous city in the Southern United States, the fourth-most populous city in the United States, and the sixth-most populous city in North America, with a population of 2,304,580 ...
, is the largest unzoned city in the United States. Less than two years later, the Supreme Court decided '' Nectow v. City of Cambridge'' (1928). In ''Nectow'', the Court overturned a zoning ordinance for violating the 14th Amendment due process clause.


Euclid

The Ambler tract remained undeveloped for 20 years until
General Motors The General Motors Company (GM) is an American multinational automotive manufacturing company headquartered in Detroit, Michigan, United States. It is the largest automaker in the United States and was the largest in the world for 77 years bef ...
built an aircraft plant there during World War II and later a GM
Fisher Body Fisher Body was an automobile coachbuilder founded by the Fisher brothers in 1908 in Detroit, Michigan. A division of General Motors for many years, in 1984 it was dissolved to form other General Motors divisions. Fisher & Company (originally All ...
plant until the 1970s. On June 9, 2016, the City of Euclid and the Euclid Landmarks Commission dedicated an Ohio Historical Marker at the Euclid Police Mini-Station on HGR Industrial Surplus’ property at 20001 Euclid Avenue, Euclid, Ohio, to formally recognize the site at the center of the U.S. Supreme Court case.Tabasso, Gina
"Historical marker erected to dedicate landmark zoning case"
HGR Industrial Surplus. Retrieved 2016-07-06.


See also

*''
Grape Bay Ltd v Attorney-General of Bermuda ''Grape Bay Ltd v Attorney-General of Bermuda'' UKPC_43


_Notes


_References

*Wolfe,_Michael_Allan_(2008)._The_Zoning_of_America:_Euclid_v._Ambler._Lawrence,_University_Press_of_Kansas._


_External_links

* *
Village_of_Euclid_v._Ambler_Realty_Co._Case_Brief_by_4_Law_School
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'' UKPC_43


_Notes


_References

*Wolfe,_Michael_Allan_(2008)._The_Zoning_of_America:_Euclid_v._Ambler._Lawrence,_University_Press_of_Kansas._


_External_links

* *
Village_of_Euclid_v._Ambler_Realty_Co._Case_Brief_by_4_Law_School
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UKPC 43


Notes


References

*Wolfe, Michael Allan (2008). The Zoning of America: Euclid v. Ambler. Lawrence, University Press of Kansas.


External links

* *
Village of Euclid v. Ambler Realty Co. Case Brief by 4 Law School
{{coord">41.565711">-81.5426, display=title, name=Village of Euclid, Ohio v. Ambler Realty Co. 1926 in United States case law United States Supreme Court cases United States Supreme Court cases of the Taft Court United States land use case law Zoning in the United States Euclid, Ohio Takings Clause case law