ABSTRACT
A major purpose for the establishment of zoning was to protect the exclusivity of single-family housing development. Supporters of zoning contended that single-family developments were frequently invaded by adverse and incompatible uses that were destructive to home ownership. The six-to-three U.S. Supreme Court decision in Euclid v. Ambler, which ruled that zoning was a constitutionally valid limitation on the exercise of property rights,1 was authored by Justice George Sutherland, who is usually identified as a staunch conservative. Apparently he set aside his ideological propensities because he was persuaded that zoning was required to preserve the integrity of home ownership. Very often, he wrote, “the apartment house is a mere parasite, constructed in order to take advantage of the open spaces and attractive surroundings created by the residential character of the district.”2
