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Law School Case Brief

Euclid v. Ambler Realty Co. - 272 U.S. 365, 47 S. Ct. 114 (1926)


Before a zoning ordinance can be declared unconstitutional, it must be said that its provisions are clearly arbitrary and unreasonable, having no substantial relation to the public health, safety, morals, or general welfare. 


Ambler Realty Company ("Ambler") owned of a tract of land containing 68 acres. The land was situated in the westerly end of the Village of Euclid, abutting on Euclid Avenue to the south and the Nickel Plate railroad to the north. Adjoining the tract, both on the east and on the west, there had been laid out restricted residential plats upon which residences were erected. On Nov. 13, 1922, an ordinance was adopted by the Village Council, establishing a comprehensive zoning plan for regulating and restricting the location of trades,  industries, apartment houses, two-family houses, single family houses, etc., the lot area to be built upon, the size and height of buildings, etc. Ambler asserted that because of the building restrictions imposed, the ordinance operated to reduce the normal value of its property, and to deprive it of liberty and property without due process of law. The municipal corporation and building inspector argued that the ordinance passed constitutional muster and was enforceable. 


Did the zoning ordinance of the Village of Euclid violate Ambler's constitutional protection of substantive due process?




The United States Supreme Court held that the district court clearly had equitable jurisdiction over the matter and further held that the ordinance, in its general scope and dominant features, was a valid exercise of authority. Ambler had not suffered or been threatened with an injury that entitled it to challenge the constitutionality of the ordinance. The restrictions imposed bore a rational relation to the health and safety of the community.

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