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.
Appellee, Amber Realty Company (Amber Realty), was the owner of a tract of land containing 68 acres, situated in the westerly end of the village, abutting on Euclid Avenue to the south and the Nickel Plate railroad to the north. On November 13, 1922, an ordinance was adopted by the council of the Village of Euclid, 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. The entire area of the village is divided by the ordinance into six classes of use districts, denominated U-1 to U-6. Amber Realty’s tract of land comes under U-2, U-3 and U-6. After the imposition of the zoning plan, Amber Realty instituted an action against the village and its building inspectors. According to Amber Realty, because of the building restrictions imposed, the ordinance operated to reduce the normal value of his property, and to deprive him of liberty and property without due process of law; thereby, violating his Fourteenth Amendment rights. The village and the building inspectors, on the other hand, argued that the ordinance passed constitutional muster and should have been enforced. The United States District Court for the Northern District of Ohio held that the ordinance was unconstitutional and void, and enjoined its enforcement. The municipal corporation and its inspector sought review.
Was the ordinance, which established a comprehensive zoning plan in the Village of Euclid, constitutional?
The Court held that the ordinance, in its general scope and dominant features, was a valid exercise of authority. According to the Court, Amber Realty’s property had not suffered or been threatened with an injury that entitled it to challenge the constitutionality of the ordinance. The Court opined that the restrictions imposed bore a rational relation to the health and safety of the community.