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Property Law Keyed to Kurtz
Village of Euclid v. Ambler Realty Co.
Citation:
272 U.S. 365 (1926)
ProfessorTodd Berman
CaseCast™ – "What you need to know"
Facts
In 1922, the Village of Euclid, a suburb of Cleveland with a population between 5,000 and 10,000, adopted a comprehensive zoning ordinance that divided the village into six use districts, three height districts, and four area districts. The ordinance imposed various restrictions on the development and use of land within each district. Ambler Realty owned a 68-acre tract of land in Euclid that abutted Euclid Avenue to the south and the Nickel Plate railroad to the north. Under the ordinance, this tract was divided into three use zones: the first 620 feet north of Euclid Avenue was zoned U-2 (single and two-family dwellings), the next 130 feet was zoned U-3 (allowing apartments, hotels, churches, etc.), and the remainder was zoned U-6 (industrial uses). Ambler Realty claimed that the ordinance significantly reduced the value of its property, from approximately $10,000 per acre for industrial use to $2,500 per acre for residential use, and sought an injunction against the enforcement of the ordinance on the grounds that it violated the Due Process Clause of the Fourteenth Amendment.
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