Facts of the Case
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.
Questions
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?
Conclusions
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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. While Ambler had standing to sue, the Court rejected its arguments on the constitutionality of the zoning ordinance, which it found neither arbitrary nor unreasonable. Applying a deferential standard of review, as the Court typically applies to constitutional challenges to economic regulations, the Court held the ordinance did not exceed the local government’s police power. Zoning regulations, the Court explained, will generally be upheld as long as there is some connection to the public welfare.