Landmark Supreme Court Case: Village of Euclid v. Amber Realty Co. (1926)
Village of Euclid v. Amber Realty Co. (1926) is the 51st landmark Supreme Court case, the 22nd in the Economics module, featured in the KTB Prep American Government and Civics series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:
- Foreign Policy
- Science & Technology
- Public Safety
- Death Penalty
- Speech, Press, and Protest
- Criminal Justice
- Politics, Society, Freedom, and Equality
The Supreme Court
The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.
The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.
The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.
Court of Appeals
In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.
The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.
A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.
The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.
Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.
There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.
Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.
Village of Euclid v. Amber Realty Co. (1926)
Village of Euclid Facts:
The Ambler Realty Company owned 68 acres of land in the village of Euclid, Ohio, a suburb of Cleveland. On November 13, 1922, The village, in an attempt to prevent industrial Cleveland from growing into and subsuming Euclid and prevent the growth of industry which might change the character of the village, developed a zoning ordinance based upon 6 classes of use, 3 classes of height and 4 classes of area. The property in question was divided into three use classes, as well as various height and area classes.
Ambler Realty’s land spanned multiple districts, and the company was therefore significantly restricted in the types of buildings it could construct on the land. They sued the village, arguing that the zoning ordinance had substantially reduced the value of the land by limiting its use, violating the Fourteenth Amendment’s protections of liberty and property described in the Due Process and Equal Protection Clauses. A federal district court agreed and issued an injunction against enforcement of the ordinance.
Q: Did the village of Euclid’s zoning ordinance violate Ambler Realty’s rights to liberty and property under the Due Process and Equal Protection Clauses of the Fourteenth Amendment?
A: No. The speculative damages claimed by Ambler Realty were insufficient to invalidate an otherwise valid exercise of the village’s police power.
Village of Euclid Conclusion
6-3 holding the zoning ordinance was not an unreasonable extension of the village’s police power and did not have the character of arbitrary fiat, and thus it was not unconstitutional. Ambler Realty had offered no evidence that the ordinance had any effect on the value of the property in question, but based their assertions of depreciation on speculation only which was not a valid basis for a claim of takings. The challenger in a due process case would have to show that the law in question is discriminatory and has no rational basis which Euclid’s zoning ordinance in fact did have.
Zoning ordinances, regulations and laws must find their justification in some aspect of police power and asserted for the public welfare. Benefit for the public welfare must be determined in connection with the circumstances, the conditions and the locality of the case meaning they will generally be upheld. Village of Euclid was the first significant case regarding the relatively new practice of zoning, and served to substantially bolster zoning ordinances in towns nationwide in the United States and in other countries of the world including Canada.
Next Economics Case: Home Building & Loan Association v. Blaisdell (1934)
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