Land-use regulation in the twentieth-century United States received a long-lasting endorsement from the Supreme Court in its 1926 ruling in Euclid v. Ambler Realty. The legal case arose out of Euclid, Ohio, a Cleveland suburb, and involved a well-planned assault on zoning based on the constitutional claim that zoning infringed property rights without due process of land. The trial judge agreed with the challenge but the Supreme Court reversed, siding with the City of Euclid in a ruling that surprised many observers. One surprise was the considerable deference the Court showed to municipal regulators. The Court institutionalized this deference by erecting a high hurdle for landowners who sought to invalidate such ordinances in the future. Also surprising was the opinion's author, Associate Justice George Sutherland, who typically sided with conservative colleagues in striking down regulatory schemes. (As Wolf notes, however, Sutherland was not the only conservative to side with the City.) Without explanation the Supreme Court held the case over for oral argument a second time, fueling speculation, then and ever since, about backroom maneuvering. The Court's opinion remains its most important land-use ruling. Indeed, the Court's current interpretation of the due process clause differs little from the skeletal view it presented in 1926.

Euclid was highly visible even before the Supreme Court ruled. Representing the landowner/developer was Newton Baker, former secretary of war under Woodrow Wilson. The federal trial judge who struck down Euclid's zoning ordinance, David C Westenhaver, was well known for sentencing Eugene Debs in 1918 to ten years in prison for violating the Espionage Act of 1917. Filing prominent amicus briefs on behalf of the fledging Ohio and National Conferences on City Planning was Alfred Bettman, a key player in promoting zoning and drafting the Standard State Zoning Enabling Act. Newton Baker viewed the dispute as a national test case and predicted the Supreme Court would invalidate zoning. The city-planning organizations viewed the case as a sword aimed at the heart of their young profession. Only the City of Euclid viewed it as a dispute limited to the sixty-eight acres of land that Ambler Realty wanted to devote entirely to industrial uses and that the City hoped would include some residences.

Michael Allan Wolf ably explores Euclid in this volume, published by the University Press of Kansas in its important book series, Landmark Law Cases & American Society, edited by Peter Charles Hoffer and N. E. H. Hull. A prominent professor of land-use and local government law at the University of Florida, Wolf has spent years digging into the history of this dispute, following up on every participant, sifting through private papers, studying the origins of zoning, and linking zoning's rising popularity to urbanization and industrialization, the City Beautiful movement, and Progressive-era professionalization. Wolf pays close attention to the influential Zoning Proposal adopted by New York City in 1916 and to the detailed 1913 Report on urban land-use ills. He also considers the likelihood that zoning's popularity reflected desires by community leaders to segregate neighborhoods, creating residential enclaves that excluded not only industry and offices but immigrants, poor people, and racial minorities. In his detailed, engaging exploration, Wolf highlights a fact that readers of Euclid typically misconstrue. Ambler Realty asserted that Euclid's zoning ordinance reduced its land value by 75 percent. The Court recounts Ambler Realty's claim yet, as Wolf emphasizes, never endorses it. (The City asserted that its zoning ordinance raised property values overall.) In Wolf's view the Supreme Court used Ambler Realty's contested valuation by way of emphasizing that zoning was constitutional even when it substantially lowered land values.

Writing for a mixed audience of historians, lawyers, and law students, Wolf goes beyond the 1920s to consider the plight of zoning today and to summarize the views of current critics. Wolf personally believes that the Court came to the right conclusion. Its opinion, he concludes, “serves as a model of pragmatic and well-balanced Progressive jurisprudence” (4). Still, he agrees that Euclid's strong endorsement of zoning gives powers to municipal leaders that can be, and sometimes are, abused.

Wolf's book is very strong in style and substance and deserves attention by historians and legal scholars alike. His narrative is particularly engaging, beginning with a gripping opening scene with Euclid's lawyer stuck on a train in a snow storm, returning from oral argument before the Supreme Court and trying frantically to dispatch a telegram to the Court. More could be said about the urban ills that led cities to embrace zoning—in his effort to make sure we know zoning's dark side, Wolf almost shortchanges the ills and dark sides of no zoning. In all, though, the book is first rate—cleanly written, thorough, and attentive to personalities and big issues alike. The important story Wolf tells so well is central to many strands of America's path.