Ambler Realty v. Euclid (1924)

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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)


  • 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.


  • 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.


An ordinance that interferes with an owner's use of private property constitutes a taking under the 5th Amendment.


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.



This case is appealed & decided by SCOTUS 2 years later in Village of Euclid v. Ambler Realty Co. (1926).