Village of Euclid v. Ambler Realty Co.
Citation: 272 U.S. 365 (U.S. 1926)
Facts
The Village of Euclid, Ohio, adopted a comprehensive zoning ordinance dividing the village into districts with restrictions on land use (residential, commercial, industrial) and building dimensions. Ambler Realty owned 68 acres it planned to develop industrially; the zoning ordinance reduced the land’s value from 2,500 per acre for residential-only use. Ambler challenged the ordinance as an unconstitutional deprivation of property without due process.
Issue
Is a comprehensive municipal zoning ordinance a valid exercise of the police power, or does it unconstitutionally deprive property owners of their property without due process?
Holding
The Supreme Court (Sutherland, J.) upheld the Euclid zoning ordinance as a constitutional exercise of the state’s police power. Zoning regulations bear a reasonable relationship to legitimate governmental purposes — public health, safety, morals, and general welfare — and are not facially unconstitutional.
Rule
Comprehensive zoning ordinances are a valid exercise of the police power and do not violate due process if they bear a rational relation to the health, safety, morals, or general welfare of the community. The judiciary will not invalidate a zoning scheme simply because it imposes restrictions on land use.
Significance
Euclid is the constitutional foundation of American zoning law. By upholding Euclidean (use-separated) zoning, the Supreme Court enabled the comprehensive municipal land-use regulation that shaped twentieth-century American cities and suburbs. The case also illustrates the police power doctrine and the limits on substantive due process challenges to economic regulation.