Village of Euclid Ohio v. Ambler Realty Co’s Empirical Analysis
272 U.S. 365 · 1926
Citation profile
1,135 federal appellate · 333 district · 2,804 state decisions
How this case has been cited
Cited by 5,588 later decisions (239 by the Supreme Court) — most recently April 2025 · most notably Village of Arlington Heights v. Metropolitan Housing Development Corp. (1977), Joshua Deshaney, a Minor, by His Guardian Ad Litem, and Melody Deshaney,s v. Winnebago County Department of Social Services, et al. (1989)
1,135 federal appellate · 333 district · 2,804 state decisions — followed in 50 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Boyd v. United States · Pierce v. Society of the Sisters of the Holy Names of Jesus and Mary Same · Pennsylvania Coal Co. v. Mahon · Mugler v. State of Kansas State of Kansas Tufts
Cited together with Penn Central Transportation Co. v. New York City · Village of Belle Terre v. Boraas · Agins v. City of Tiburon · Hadacheck v. Sebastian · Pennsylvania Coal Co. v. Mahon
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 5,588 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“clearly arbitrary and unreasonable, having no substantial relation to the public health, safety, morals, or general welfare.”
237 later decisions quote this exact passage · from the majority““To hold that for zoning purposes a district could not be classified as residential merely because a few isolated business houses had been already established therein would practically prohibit the exercise of the right of zoning. As we have seen by the foregoing quotations from the Euclid case, neither the mere fact that the natural development of a district was toward industrial enterprise and that the normal and reasonably to be expected future use of certain property was for industry and trade purposes, nor the fact that property, if used for business purposes, would be of more value than if used for residential, will justify a court in finding unconstitutional an ordinance which checks or defeats such development or diverts it to another district.””
2 later decisions quote this exact passage · from the majority““The Supreme Court of the United States, however, not only pointed out that it was simply validating the ordinance in its ‘general scope’ and not in detail, but, in addition, the court expressly removed from consideration that portion of the ordinance which restricted the use of property for church purposes, saying at page 385: '* * * there is nothing in the record to suggest that any damage results from the presence in the ordinance of those restrictions relating to churches, schools, libraries and other public and semi-public buildings * * *. For present purposes the provisions of the ordinance in respect of these uses may, therefore, be put aside as unnecessary to be considered.’ The Village of Euclid case, while deciding that commercial and industrial structures may, consistently with the Fourteenth Amendment, be excluded from residential districts, decides nothing with regard to the exclusion of humanitarian, public and semi-public uses like churches, schools and libraries.””
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.