Landmark Supreme Court Cases: Village of Euclid v. Ambler Realty Co., 272 U.S. 265 (1926)
Euclid v. Ambler, was a landmark decision in the area of zoning. It dealt with the city of Euclid, which enacted various zoning regulations, in order to keep certain areas of the city within certain types of use, such as residential and industrial. In the case, Ambler Realty held a piece of property, which it argued was financially disadvantaged by the new zoning rules. The lower court held that the ordinance constituted an unconstitutional taking of the property (without due compensation, or process), thus holding the regulation unconstitutional.
The Supreme Court reversed, holding that the zoning ordinance was a reasonable use of the village's police power (which is generally reserved to the states and their subsidiaries), and that it was not arbitrary, thus it was not unconstitutional.
Zoning Laws Generally Constitutional
Additionally, the Court found Ambler failed to offer any evidence in fact of disparate economic impact on the value of the property in question, and that the assertions of depreciation were based solely on speculation. The court held that speculation was not a valid basis for a claim of takings.
In terms of Ambler's 14th Amendment arguments, 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 in order to prevail. The Court found that Euclid's justification for zoning laws was rationally based, and thus sufficient to pass constitutional scrutiny.
For all of the foregoing reasoning, Euclid is thus known as the seminal case in zoning law.
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