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and limited auxiliary uses,50and only a third portion open to a broad number of residential, commercial, and industrial uses.si Ambler alleged that it had held the land for a number of years for the purposes of developing it as industrial land, and that if put to industrial use the land would be worth four times as much than if it was zoned residential. s� Thus, Ambler argued, the zoning constituted an unconstitutional taking under the Fourteenth Amendment of the United States Constitution. s3 At the trial court, the United States District Court for the Northern District of Ohio held that the ordinance was unconstitutional and void, and enj oined its enforcement.54 Euclid sought review. The United States Supreme Court upheld the zoning as based on the Village's inherent police power. ss While the Court found that the exact line between the legitimate and illegitimate use of the police power could not be clearly delineated as it varies with facts and circumstances, the Court nonetheless held that zoning can be based on more than the narrow prevention of common law nuisance.56 The Court held that before a zoning ordinance can be declared unconstitutional, the provisions must be clearly arbitrary and unreasonable, having no substantial so Euclid at 380-381. Permitted auxiliary uses included churches, schools, cultural, and recreational use. 51 Id s�Id at384-385. 53 Id. at 3 85. 54 Id 55 T.7 1 Ll 56 Euclid at 388 citing Welch v. Swasey, 214 U.S. 91 (1909); Hadachek v. Los Angeles, 239 U.S. 394 (1915); Reinman v. Little Rock, 237 U.S. 171 (1915); Cusack v. City of Chicago 242 U.S. 525, 529-530 (1917). Before Euclid, cases had supported the municipal use of the police power to prohibit uses which could cause nuisances. 16