Ambler Realty Co. v. Village of Euclid, Ohio Case Brief Summary | Law Case Explained

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Ambler Realty Co. v. Village of Euclid, Ohio | 297 F. 307 (1924)
The Village of Euclid was a suburb of Cleveland. In the early 1920s, it was mostly farmland with a few thousand inhabitants, but the village was forecast to have the potential to accommodate several hundred thousand people if fully built up. In an effort to guide development, the village adopted an ordinance that restricted the use of land. The constitutionality of this ordinance is the subject of Ambler Realty versus Village of Euclid, Ohio.
Though Euclid was still bucolic, manufacturing plants had sprung up along the railroad that ran through the village. The main thoroughfare, Euclid Avenue, was already a major commercial street in Cleveland, and retail establishments were beginning to set up in Euclid.
The village invoked its police power and passed a zoning ordinance that imposed various restrictions on land use within the village limits. It created six classes of uses and placed various height restrictions on buildings, as well as restricting which lots could be built on and creating setbacks.
Ambler Realty owned 68 acres of unimproved land in Euclid, not far from the Cleveland city limits. The ordinance restricted Ambler’s use of its land. Under the ordinance, its Euclid Avenue frontage could be used only for single-family dwellings. The next 470 feet could only be used for two-family dwellings. The 130 feet behind that was restricted to apartments. Only the remaining 1200 feet north of the railway could be used for industry and manufacturing.
Ambler protested that the normal and reasonable use of its land was for retail and manufacturing applications. It claimed that the ordinance made the land hard to sell and depressed its market value by several hundred thousand dollars.
The village maintained that the ordinance was a valid exercise of police power, which allowed it to legislate in the interests of public health and safety. The village argued that as long as an owner maintained legal title to property, then the property hadn’t been taken, even if the owner’s right to use it was limited in a way that decreased its value.
Ambler asked the court to declare the ordinance null and void. It argued that the ordinance resulted in an unconstitutional taking of private property without compensation.
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