Village of Euclid v. Ambler Realty Co.

Supreme Court of the United States · 1926 · Property

PropertyConstitutional Lawzoningpolice powerland useEuclidean zoningzoningpolice power

Facts

The Village of Euclid adopted a comprehensive zoning ordinance dividing the village into use, height, and area districts and regulating where residential, business, apartment, and industrial uses could be located. Ambler Realty owned a 68-acre vacant tract, part of which fell in U-2 and U-3 districts near Euclid Avenue and the remainder in U-6, and alleged the ordinance greatly reduced the land's value and marketability for industrial, commercial, and apartment uses. The record showed that the expected development of the frontage near Euclid Avenue was for trade and commercial purposes and the remainder for industrial and trade purposes. Ambler attacked the ordinance as a whole, claiming it deprived it of property without due process and denied equal protection.

Issue

Whether Euclid's comprehensive zoning ordinance, as applied in its general scope and dominant features to Ambler Realty's land, was an unconstitutional exercise of the police power because it was arbitrary, unreasonable, and confiscatory under the Fourteenth Amendment. Also, whether Ambler's suit was premature because it had not first sought a permit or administrative relief.

Rule

Comprehensive zoning regulations must be justified under the police power as bearing a substantial relation to the public health, safety, morals, or general welfare. In evaluating such regulations, courts consider use in relation to circumstances and locality, may look to nuisance law by analogy, and if the validity of the legislative classification for zoning purposes is fairly debatable, the legislative judgment must be allowed to control. When an ordinance is attacked as a whole, the court may uphold it in its general scope and dominant features without deciding the validity of every detailed provision.

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The town council of Brookhaven, Missouri adopts a comprehensive zoning code that bars retail shops and apartment buildings from several residential districts. Maya Fulton owns vacant land on a major road and alleges the code immediately slashed the tract's market value because buyers for commercial and apartment development have walked away; she sues to enjoin enforcement without first applying for a permit or seeking a variance.

Is Maya's suit most likely premature?

Explanation. The majority held that a broad attack on a zoning ordinance was not premature where the complaint alleged that the ordinance itself presently reduced value and marketability and threatened continuing injury. In that setting, the ordinance's existence may constitute a present invasion of property rights sufficient for equity, even without a denied permit. But that does not mean the owner automatically wins on the merits.