Court: Supreme Court of the United States; May 14, 1928; Federal Supreme Court; Federal Appellate Court
A zoning ordinance in Cambridge categorizes the city into residential, business, and unrestricted districts, each with specific building regulations. The plaintiff's land is designated as R-3, permitting only residential structures and similar uses. The plaintiff challenged the ordinance, claiming it violated the Fourteenth Amendment by depriving him of property without due process. He sought a mandatory injunction for the city to consider his application for a building permit without adhering to the ordinance. The case was referred to a master, who reviewed the facts and found that the plaintiff owned a 140,000 square foot tract, of which 29,000 square feet was under dispute. This tract was adjacent to unrestricted land and near industrial sites, including a Ford factory. The zoning restrictions prevented business use of the locus, impacting a sale contract for $63,000 that fell through due to the ordinance. The ordinance's application was upheld by the court, which dismissed the plaintiff's case.
The master concluded that the land in question cannot be effectively used for residential purposes due to insufficient potential returns on investment. It was determined that classifying the land as part of a residential district would not enhance the health, safety, convenience, or general welfare of the local inhabitants, particularly considering the surrounding industrial and railroad uses. The court supported the notion that judicial intervention in zoning decisions should only occur if such actions are deemed arbitrary or irrational without a reasonable foundation related to public health or welfare.
An analysis of the city's zoning map, in conjunction with the master’s findings, indicated that including the disputed land in the residential zone is not essential to the overall zoning plan. Adjusting the boundary line of the residential district is feasible and should be done. However, the court emphasized that zoning restrictions must have a substantial relation to public health, safety, morals, or general welfare. The master’s finding, which was affirmed by the court, indicated that the existing zoning does not promote these public interests. Consequently, the court ruled that the zoning authorities' actions infringe upon the property rights protected by the Fourteenth Amendment, leading to a reversal of the judgment.
