In its 1926 opinion in Village of Euclid, Ohio v. Ambler Realty, 272 U.S. 365 (1926), the U.S. Supreme Court upheld what is known today as Euclidean zoning—use-based zoning districts regulating residential and nonresidential uses together with area and bulk standards. At issue in Village of Euclid was the exercise of the police power. Were the land use regulations reasonable? Did they evince a substantial relation to the public health, safety, morals, or general welfare?

The philosophy and application of Euclidean zoning are seen far and wide, from state to commonwealth. Today, zoning is a subset of what is known as “land use.” That term encompasses both zoning and subdivision/land development. Pennsylvania courts have said that zoning relates to the use of the land, and subdivision/land development involves the details of improvement to the property and the construction of those improvements.