## Facts

- The Village of Hudson enacted zoning provisions creating an Architectural and Historic Board of Review to regulate external building design and appearance to protect property values, preserve community character, and prevent blight.
- Albrecht, Inc. submitted alteration plans for a building in a shopping center; the village building inspector and the Board approved the submitted plans.
- During construction, the inspector discovered Albrecht was making additional exterior changes (including on the street-facing portion) that were not included in the approved plans.
- The inspector issued a stop-work order; Albrecht did not comply and completed the unapproved alterations.
- The Village sued for injunctive relief to halt further work and require removal of the unapproved exterior alterations.

## Issues

1. Whether an architectural review ordinance regulating building appearance is a valid exercise of municipal police power when justified by public purposes beyond aesthetics (including protection of property values and general welfare).
2. Whether the ordinance’s design-review criteria were so vague or standardless as to be an unconstitutional delegation of authority.

## Decision

- The Supreme Court of Ohio reversed the court of appeals and upheld the ordinance.
- The Court held the ordinance was not based solely on aesthetics; it furthered legitimate public purposes, including protecting real estate values and preventing deterioration and blight.
- The Court held the ordinance contained sufficiently definite guiding standards (including reference to standard, accepted architectural principles and compatibility with village character) to constrain the Board’s discretion.
- The Court approved requiring Albrecht to submit amended plans for Board review under the ordinance rather than exempting the unapproved changes from review.

## Legal Principles

- Municipal police power permits design-review regulation of exterior appearance when the regulation is reasonably connected to the general welfare, including protection of property values and community character.
- Aesthetic considerations may be considered as part of the general welfare when tied to other legitimate objectives and implemented through standards that meaningfully guide administrative decision-making.
- Zoning and design-review standards may be stated in general terms (e.g., compatibility with character; accepted architectural principles) without being void for vagueness, so long as they provide practical guidance and limit arbitrary enforcement.

## Conclusion

Ohio sustained Hudson’s architectural review scheme as a constitutional exercise of police power because it served general-welfare goals beyond aesthetics and provided adequate standards for Board review, requiring the property owner to submit unapproved exterior changes for review under the ordinance.


Village of Hudson v. Albrecht, Inc., 9 Ohio St. 3d 69, 458 N.E.2d 852 (Ohio 1984)