Village of Euclid v. Ambler Realty Co.

Brief Fact Summary.

Plaintiff, a landowner in Defendant’s residential suburb, claimed that Defendant was depriving her of due process under the Fourteenth Amendment of the United States Constitution and the Ohio Constitution. Specifically, Plaintiff claimed that Defendant’s actions of partitioning her land based on the land’s use was unconstitutional. The district court held in Plaintiff’s favor, and Defendant appealed to the Supreme Court of the United States.

Synopsis of Rule of Law.

A municipal zoning regulation is deemed to be constitutional when the regulation is not clearly arbitrary nor unreasonable, thus it must have a substantial relation to the public health, safety, morals, or general welfare.

Facts.

Ambler Realty Co. (“Plaintiff”) was the owner of land in the Village of Euclid (“Defendant”). Defendant was known to be a residential suburb in Cleveland, Ohio. In 1922, Defendant authorized comprehensive zoning ordinances and composed a board of zoning appeals to enforce the ordinances. Under the regulation, districts were created based on the class of use, which encompassed purely residential use, mixed use, commercial use, and industrial use. Due to the ordinance, Plaintiff’s land was partitioned in regards to the types of uses that were authorized on the land. Also, parts of Plaintiff’s land were zoned in a manner to forbid the emergence of industry. Plaintiff instigated this action against Defendant on the ground that the zoning ordinance constituted a violation of the Fourteenth Amendment of the United States Constitution and the Ohio Constitution. Plaintiff alleged that the ordinance substantially decreased Plaintiff’s land’s value and dissuaded potential buyers. Defendant motioned to dismiss the case claiming that the zoning regulations were not being enforced against Defendant because Plaintiff did not apply for a building permits. Defendant’s motion was denied, and the district court found that the Defendant’s ordinance was unconstitutional. Therefore, the district court enjoined its enforcement. Defendant appealed to the United States Supreme Court.

Issue.

Whether a municipal zoning regulation is deemed to be constitutional when the regulation is neither clearly arbitrary nor unreasonable, thus it must have a substantial relation to the public health, safety, morals, or general welfare.

Held.

Yes, a municipal zoning regulation is deemed to be constitutional when the regulation is not clearly arbitrary nor unreasonable, thus it must have a substantial relation to the public health, safety, morals, or general welfare.

Discussion.

The district court improperly held that Defendant’s zoning ordinance was unconstitutional. Zoning restrictions are only deemed unconstitutional when it is “clearly arbitrary and unreasonable” and without “substantial relation to the public health, safety, morals, or general welfare.” A state is given the power to pass zoning regulations from states’ police powers. Further, zoning ordinances were specifically designed to handle the difficulties created by the rising urban populations. Due to this rise in urban population, the applications of constitutional guarantees by courts are required to have some “elasticity.” Thus, the propriety of a zoning ordinance must be evaluated on a case-by-case basis. Under the laws of nuisance, one may not use his or her property to in a manner that harms another’s use of their property. As such, the same principle may be used to determine the scope of the power to control property use. An ordinance that restricts industrial use of property may be over-inclusive because these types of ordinances do not “pass…the bounds of reason and assume…the character of a merely arbitrary fiat.” Purity Extract Co. v. Lynch, 226 U.S. 192 (1912). Therefore, these over-inclusive ordinances are commonly valid. However, an ordinance that excludes all commercial activity is a difficult inquiry, and there is a trend among state courts to sustain such ordinances, rather than overturn them. Moreover, experts have previously agreed that these forms of ordinances tend to make it easier to prevent fires and accidents, reduce noise, and preserve residential areas. As such, these zoning ordinance regulations are proper as long as they are neither clearly arbitrary nor unreasonable and absent any correlation to the general welfare. Here, although Defendant is hindering the current course of industrial development in Cleveland, Defendant is operating in a manner that is well within its power. Also, Plaintiff is not required to wait until a building permit has been denied to challenge the constitutionality of the ordinance. Finally, although the zoning restriction scheme here may well prove to be unconstitutional in application, it is constitutional on its face. Therefore, the district court’s decision is reversed.