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Commentary

Euclid Revisited

 

Abstract

Village of Euclid v. Ambler Realty Co., 272 U.S. 365 (1926), was a suit to enjoin the enforcement of a zoning ordinance on the ground that the realty company's property had been taken. As everyone knows, the landowner lost, and Justice Sutherland's decision in Euclid became the main precedent establishing the constitutionality of comprehensive zoning ordinances. The fortuitous link between the defendant and the father of geometry gave the first generation of zoning ordinances an apt name.

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