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Ambler Realty v. Euclid (1924): Difference between revisions
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{{Infobox Case Brief | {{Infobox Case Brief | ||
|court=United States District Court for the Northern District of Ohio | |court=United States District Court for the Northern District of Ohio | ||
|citation=297 F. 307 | |||
|date=January 14, 1924 | |date=January 14, 1924 | ||
|subject=Property | |subject=Property | ||
|facts=* The village of Euclid was a suburb of Cleveland, Ohio in the early 1920s. The village had a potential for population growth and economic boom. The village passed an ordinance to restrict land use. | |||
|facts=The village of Euclid was a suburb of Cleveland, Ohio in the early 1920s. The village had a potential for population growth and economic boom. The village passed an ordinance to restrict land use. | * The village of Euclid created 6 classes of land uses, imposed height restrictions on buildings, and created [https://www.youtube.com/watch?v=GPGKShCuC3E setback]s. | ||
* Ambler Realty Company owned 68 acres of un-improved land in Euclid, Ohio. The ordinance forced Ambler Realty to limit its percentage of land for industry and manufacturing to a small percentage. | |||
The village of Euclid created 6 classes of land uses, | |||
Ambler Realty Company owned 68 acres of un-improved land in Euclid, Ohio. The ordinance forced Ambler Realty to limit its percentage of land for industry and manufacturing to a small percentage. | |||
|procedural_history=Ambler asked the U.S. federal district court in northern Ohio to invalidate the Euclid ordinance. | |procedural_history=Ambler asked the U.S. federal district court in northern Ohio to invalidate the Euclid ordinance. | ||
|arguments=Ambler argued that the Euclid ordinance depressed the market value of its property by several $100,000 in the 1920s. | |arguments=* Ambler argued that the Euclid ordinance depressed the market value of its property by several $100,000 in the 1920s. | ||
* Euclid argued that the ordinance was a valid exercise of its police power in the state of Ohio for [[zoning in the United States]]. | |||
Euclid argued that the ordinance was a valid exercise of its police power in the state of Ohio for [[zoning in the United States]]. | |holding=An ordinance that interferes with an owner's use of private property constitutes a [[Constitution_of_the_United_States#Takings_Clause|taking]] under the [[5th Amendment]]. | ||
|reasons=Judge [https://www.fjc.gov/node/1389636 David Westenhaver] reasoned that any ordinance that (1) limits the free use of property or (2) decreases property value interferes with the right to property, and it is, therefore, a taking. | |||
|rule=[https://www.quimbee.com/keyterms/zoning-ordinance Zoning ordinance] | |||
|comments=This case is appealed & decided by SCOTUS 2 years later in ''[[Village of Euclid v. Ambler Realty Co.]]'' (1926). | |||
|case_text_links={{Infobox Case Brief/Case Text Link | |case_text_links={{Infobox Case Brief/Case Text Link | ||
|link=https://case-law.vlex.com/vid/ambler-realty-co-v-893733351 | |link=https://case-law.vlex.com/vid/ambler-realty-co-v-893733351 | ||
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}}{{Infobox Case Brief/Case Text Link | }}{{Infobox Case Brief/Case Text Link | ||
|link=https://www.quimbee.com/cases/ambler-realty-co-v-village-of-euclid-ohio-297-f-307-1924 | |link=https://www.quimbee.com/cases/ambler-realty-co-v-village-of-euclid-ohio-297-f-307-1924 | ||
|case_text_source=Quimbee | |source_type=Video summary | ||
|case_text_source=Quimbee | |||
}} | }} | ||
}} | }} | ||
Latest revision as of 01:09, May 13, 2024
| Ambler Realty v. Euclid (1924) | |
| Court | United States District Court for the Northern District of Ohio |
|---|---|
| Citation | 297 F. 307 |
| Date decided | January 14, 1924 |
| Overturned by | |
| Euclid v. Ambler Realty (1926) | |
| Followed by | |
| Euclid v. Ambler Realty (1926) | |
Facts
- The village of Euclid was a suburb of Cleveland, Ohio in the early 1920s. The village had a potential for population growth and economic boom. The village passed an ordinance to restrict land use.
- The village of Euclid created 6 classes of land uses, imposed height restrictions on buildings, and created setbacks.
- Ambler Realty Company owned 68 acres of un-improved land in Euclid, Ohio. The ordinance forced Ambler Realty to limit its percentage of land for industry and manufacturing to a small percentage.
Procedural History
Ambler asked the U.S. federal district court in northern Ohio to invalidate the Euclid ordinance.
Arguments
- Ambler argued that the Euclid ordinance depressed the market value of its property by several $100,000 in the 1920s.
- Euclid argued that the ordinance was a valid exercise of its police power in the state of Ohio for zoning in the United States.
Holding
An ordinance that interferes with an owner's use of private property constitutes a taking under the 5th Amendment.
Reasons
Judge David Westenhaver reasoned that any ordinance that (1) limits the free use of property or (2) decreases property value interferes with the right to property, and it is, therefore, a taking.
Rule
Comments
This case is appealed & decided by SCOTUS 2 years later in Village of Euclid v. Ambler Realty Co. (1926).
