EUCLID v. AMBLER REALTY CO.
The Ambler Realty Company owned 68 acres of land in the village of Euclid, Ohio, a suburb of Cleveland. On November 13, 1922, the village council passed a zoning ordinance dividing the village into several districts. The ordinance defined the use and size of buildings permissible in each district. Ambler Realty's land spanned multiple districts, and the company was therefore significantly restricted in the types of buildings it could construct on the land. Ambler Realty filed suit against the village, claiming the ordinance violated the Fourteenth Amendment's protections of liberty and property described in the Due Process and Equal Protection clauses. A federal district court agreed and issued an injunction against enforcement of the ordinance.
Did the village of Euclid's zoning ordinance violate Ambler Realty's rights to liberty and property under the Due Process and Equal Protection clauses of the Fourteenth Amendment?
No. In a 6-3 opinion authored by Justice George Sutherland, the Court concluded that the speculative damages claimed by Ambler Realty were insufficient to invalidate an otherwise valid exercise of the village's police power. Sutherland's opinion, after noting that several lower courts had upheld zoning laws, and that numerous investigations and studies had found the laws beneficial, stated that such facts "are sufficiently cogent to preclude us from saying…that such provisions are clearly arbitrary and unreasonable, having no substantial relation to the public health, safety, morals, or general welfare." Given the law's valid basis, the Court found that, although its enforcement may ultimately cause some degree of hardship to the company, it could not overturn the ordinance based solely on "the broad ground that the mere existence and threatened enforcement of the ordinance, by materially and adversely affecting values and curtailing the opportunities of the market, constitute a present and irreparable injury."