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Village of Euclid, Ohio v. Ambler Realty Co., 272 U.S. 52 (1926) was a United States Supreme Court decision (usually referred to as Euclid v. Ambler Realty). Ambler Realty owned 68 acres of land in the village of Euclid, a suburb of Cleveland. The village, in an attempt to prevent industrial Cleveland from growing into and subsuming Euclid and prevent the growth of industry which might change the character of the village, developed a zoning ordinance based upon 6 classes of use, 3 classes of height and 4 classes of area. The property in question was divided into three use classes, as well as various height and area classes. Ambler Realty sued the village, arguing that the zoning ordinance had substantially reduced the value of their property by limiting its use, amounting to deprivation of Ambler's liberty and property without due process. In lower court, Euclid moved to dismiss the complaint because Ambler Realty had failed to first take the issue to the zoning board as required by the ordinance. The lower court denied this motion and sided with Ambler Realty. The Supreme Court agreed with the denial of the dismissal motion, but overturned the outcome of the case and sided with Euclid. The Court argued that the zoning ordinance was not an unreasonable extension of the village's police power and did not have the character of arbitrary fiat, and thus it was not unconstitutional. Further, the Court found that Ambler Realty had offered no evidence that the ordinance had in fact had any effect on the value of the property in question, but based their assertions of depreciation on speculation only. The court ruled that speculation was not a valid basis for a claim of takings. Ambler Realty had argued their case on the basis of the 14th Amendment's due process clause. The Court noted that the challenger in a due process case would have to show that the law in question is discriminatory and has no rational basis. The Court found that Euclid's zoning ordinance in fact did have a rational basis. The opinion was written for the majority by Justice Sutherland, with Justices Holmes, Stone, Brandeis, Sanford, and Chief Justice Taft concurring. Justices Van Devanter, McReynolds, and Butler dissented without comment. Euclid v. Ambler Realty was the first significant case regarding the relatively new practice of zoning, and served to substantially bolster zoning ordinances.
External links
- Full text of the decision courtesy of Findlaw.com (http://laws.findlaw.com/us/272/365.html)
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