Village of Euclid v. Ambler Realty Co.

Village of Euclid, Ohio v. Ambler Realty Co.
Supreme Court of the United States
Argued January 27, 1926 Reargued October 12, 1926 Decided November 22, 1926
Full case name	Village of Euclid, Ohio, et al. v. Ambler Realty Company
Citations	272 U.S. 365 (more) 47 S. Ct. 114; 71 L. Ed. 303; 1926 U.S. LEXIS 8; 4 Ohio L. Abs. 816; 54 A.L.R. 1016
Prior history	Appeal from the United States District Court for the Northern District of Ohio
Holding
The Court held that the zoning ordinance was not an unreasonable extension of the village's police power and did not have the character of arbitrary fiat, and thus it was not unconstitutional.
Court membership
Chief Justice William H. Taft Associate Justices Oliver W. Holmes, Jr. · Willis Van Devanter James C. McReynolds · Louis Brandeis George Sutherland · Pierce Butler Edward T. Sanford · Harlan F. Stone
Case opinions
Majority	Sutherland, joined by Taft, Holmes, Brandeis, Sanford, Stone
Dissent	Van Devanter, McReynolds, Butler
Laws applied
U.S. Const. amend. XIV

Village of Euclid, Ohio v. Ambler Realty Co., 272 U.S. 365 (1926), more commonly Euclid v. Ambler, was a United States Supreme Court landmark case argued in 1926. It was the first significant case regarding the relatively new practice of zoning, and served to substantially bolster zoning ordinances in towns nationwide in the United States and in other countries of the world including Canada.

Ambler Realty owned 68 acres (0.28 km²) of land in the village of Euclid, Ohio, a suburb of Cleveland. The village, in an attempt to prevent industrial Cleveland from growing into and subsuming Euclid and prevent the growth of industry which might change the character of the village, developed a zoning ordinance based upon 6 classes of use, 3 classes of height and 4 classes of area. The property in question was divided into three use classes, as well as various height and area classes, thereby hindering Ambler Realty from developing the land for industry. Ambler Realty sued the village, arguing that the zoning ordinance had substantially reduced the value of the land by limiting its use, amounting to a deprivation of Ambler's liberty and property without due process.

In the lower court, the village moved to dismiss the complaint entirely, arguing that Ambler Realty had no right to sue in the first place without taking the issue before the Euclid Zoning Board, as required by the zoning ordinance. Euclid was basing this argument on a legal doctrine which has come to be known as the exhaustion of administrative remedies. The court denied this motion. Finding that the zoning ordinance did in fact constitute a taking by Euclid of Ambler's property, the court stated that the ordinance was unconstitutional. Thus there was no reason for the company to abide by the ordinance's requirement. Euclid's motion was denied and the lower court decided in favor of Ambler Realty. Prominent lawyer Newton D. Baker argued the case for Ambler Realty and James Metzenbaum represented Euclid.