Dobbins v. Los Angeles

Background

A woman planning to build and run a gasworks bought land inside a district the city allowed for such factories, got permits, contracted for construction, and spent money. The Los Angeles city council later amended an ordinance to shrink the allowed district and to exclude her property, and she sued claiming the change unlawfully took her property and violated the Fourteenth Amendment.

Reasoning

The Court asked whether municipal rules that look like health and safety measures can be reviewed when they act as arbitrary exclusions. Relying on prior decisions, the Court said city police-power actions are subject to judicial review when they unfairly target individuals or destroy property rights. The Court found the complaint’s facts — sudden narrowing of the permitted area after she had begun building, without adequate public-safety reasons and with an appearance of favoritism toward a rival — could show unconstitutional, arbitrary action. The Court held the demurrer should have been overruled, reversed the California Supreme Court, and sent the case back for the city to answer.

Real world impact

This ruling means property owners and businesses can ask courts to block municipal rules that appear arbitrary or discriminatory rather than genuine health or safety measures. The decision does not resolve who ultimately wins on the merits; it allows the case to proceed so courts can decide whether the city’s actions unlawfully deprived the owner of property without due process.