## Facts

- Ambler Realty Company owned approximately 68 acres in the Village of Euclid, Ohio.
- The Village adopted a comprehensive zoning ordinance dividing the municipality into multiple use, height, and area districts.
- The ordinance split Ambler’s tract among several districts and restricted industrial development that Ambler claimed was the land’s most valuable use.
- Ambler alleged the ordinance substantially reduced the land’s value and constituted an unconstitutional deprivation of liberty and property under the Fourteenth Amendment.
- The Village argued, among other defenses, that Ambler should have first sought relief through local administrative procedures.

## Issues

1. Whether the zoning ordinance was an unreasonable and arbitrary exercise of the police power, violating the Fourteenth Amendment’s Due Process Clause.
2. Whether the ordinance could be invalidated on its face based on asserted depreciation in value and predicted limits on use, absent a concrete application such as a denied permit.
3. Whether failure to pursue relief before the local board of zoning appeals barred judicial review.

## Decision

- The Supreme Court reversed the district court and upheld the zoning ordinance.
- The Court held the ordinance was not arbitrary or unreasonable and therefore did not violate the Fourteenth Amendment.
- The Court applied a deferential standard: if the ordinance’s reasonableness is “fairly debatable,” legislative judgment controls.
- The Court treated much of Ambler’s claimed injury from diminished value as conjectural and insufficient to invalidate the ordinance on its face.
- The Court permitted the suit to proceed despite arguments that Ambler had not first pursued administrative relief, but rejected the constitutional challenge on the merits.

## Legal Principles

- A zoning ordinance is constitutional if it bears a substantial relation to the public health, safety, morals, or general welfare and is not arbitrary or unreasonable.
- Comprehensive zoning that separates land uses, including limiting industrial uses in residential areas, can be justified as a preventive measure akin to nuisance control in particular locations.
- Courts presume the validity of economic and land-use regulations; a challenger must show more than debatable unreasonableness to prevail.
- Facial invalidation is disfavored where the asserted harms rest on predicted, uncertain future applications rather than concrete denials or enforcement actions.

## Conclusion

The Court sustained comprehensive municipal zoning as a legitimate exercise of the police power under the Fourteenth Amendment, holding that use-segregation rules will be upheld when their reasonableness is fairly debatable and alleged economic harms are speculative.


Vill. of Euclid v. Ambler Realty Co., 272 U.S. 365 (1926)