Euclid v. Ambler Realty Co.

By presenting their case as a constitutional issue, Ambler Realty left the door open for the village of Euclid to appeal the federal court's decision before the U.S. Supreme Court. The case was argued in Washington, D.C., on 27 January 1926 and reargued on 12 October 1926. On 22 November, the Court reversed the federal court injunction by a 6-3 vote. Justices Van Devanter, McReynolds, and Butler dissented without producing a written comment on the case.

Ambler Realty claimed that zoning diminished the value of their property, thus depriving them of both the liberty to use the land according to their own wishes and a substantial amount of potential resale value. The Court reaffirmed the importance of protecting the rights of private property ownership. Yet the Court also approved of zoning in broad terms, justifying regulation only in cases where it was designed to protect public welfare.

Justice Sutherland's written opinion noted the similarities between Euclid's statutes and the so-called "nuisance laws," with which municipalities had previously governed land use. Nuisance laws were usually written and invoked to contain problems like pollution, vice, or possible disease. The Court found that Euclid's zoning laws were similarly defensible as a means of promoting public welfare. While a few state courts opposed zoning, the Court pointed to a majority of states whose laws supported a growing societal consensus that zoning helped reduce or control residential overcrowding, traffic congestion, crime, noise, disease, and pollution.

The Court did not declare zoning to be an omnipotent principle. It was generally appropriate in Euclid's case, but the Court proposed that some laws governing use of specific parcels of land might be found to be unconstitutional. Since Ambler Realty had sought relief from Euclid's statutes only in broad terms, the Court was not required to rule on any particular instances in which the zoning regulations might have been unfair. Only the potential use of Ambler Realty's land had been at issue in their suit, but the Court found zoning rules regarding building height and breadth to be equally constitutional. Justice Sutherland noted that zoning laws could have been oppressive if applied in past eras. Now, however, the Court approved of zoning as an idea whose time had come, reflecting the increasing urbanization of American life, the arrival of automobiles, and safety concerns relating to public transit.

The Supreme Court's decision legitimized the fundamental idea of zoning in the eyes of the law. Zoning disputes were usually fought in state courts prior to the Euclid v. Ambler Realty Co. decision. Ironically, this did not change. State courts had no rule by which to guide their decisions before the Euclid conflict. The Supreme Court's ruling disposed of the debate over zoning as a concept, allowing the lower courts to more uniformly address specific issues in future individual land use cases.