Village of Euclid v. Ambler Realty Co.

The Village of Euclid, a suburb of Cleveland, Ohio, enacted a comprehensive zoning ordinance dividing the village into six use districts, three height districts, and four area districts. Ambler Realty Company owned 68 acres of vacant land that it wished to sell for industrial development. The zoning ordinance restricted much of Ambler's property to residential use, reducing its market value from $10,000 per acre (industrial) to $2,500 per acre (residential). Ambler challenged the ordinance as an unconstitutional deprivation of property without due process.

Justice Sutherland, writing for the majority, analogized zoning to the common law of nuisance, reasoning that uses inappropriate to their surroundings could be treated as nuisances. He noted that apartment buildings in single-family neighborhoods could be considered parasitic, bringing noise, traffic, and decreased property values. The Court applied a rational basis test, asking whether the zoning classifications were arbitrary and unreasonable, having no substantial relation to public health, safety, morals, or general welfare. Sutherland acknowledged that zoning could potentially be unconstitutional as applied to specific parcels but held that the ordinance survived a facial challenge. The decision left open the possibility of as-applied challenges.

Euclid legitimized comprehensive zoning as a governmental tool and triggered the rapid adoption of zoning ordinances across the United States. The case established the framework for analyzing land use regulations under the Due Process Clause and provided the constitutional foundation for modern land use planning. However, Euclidean zoning has also been criticized for promoting sprawl, segregation, and exclusionary housing practices.