Village of Euclid, Ohio v. Ambler Realty Co., U.S. Supreme Court (1926)

Facts:
Ambler Realty Co. is the owner of 68 acres in Euclid, a suburb of Cleveland, which is bounded by a principal highway, railroad, and residential areas. In 1922, an ordinance was established by the village council, establishing a comprehensive zoning plan, dividing the village into use, height, and area districts. The Ambler property was zoned as U-2 (one and two family dwellings), U-3 (one and two family dwellings and apartments), and U-6 (all uses except those prohibited). Ambler claims that the ordinance as a whole reduces the value of the land and destroys its marketability. Ambler seeks an injunction restraining enforcement of the ordinance.

Procedure:
The court below held the ordinance to be unconstitutional and void, and enjoined its enforcement.

Issue:
Is the establishment of use, height, and area restrictions and the application of these restrictions to private property an invalid exercise of police power, in that it violates the protection of the 14th Amendment to the right of property and is unreasonable and confiscatory?

Holding:
The ordinance is a valid exercise of police power. The lower court ruling was reversed.

Rationale:
The court found that the ordinance rationally related to the public health, safety, morals, and general welfare of the community and that the ordinance as a whole was not arbitrary or unreasonable.

Notes:
The enforcement of the ordinance is the building inspector, under the rules and regulations of the board of zoning appeals.
The importance of context is discussed: i.e. zoning might not be appropriate in a rural community, but is appropriate in Euclid.