In [*Mugler v. Kansas* 123 U.S. 623 (1887)](https://supreme.justia.com/cases/federal/us/123/623/), the Supreme Court ruled that prohibition of alcohol is not a taking. (Alcohol property rendered worthless.)


[*Hadacheck v. Sebastian* 239 U.S. 394 (1915)](https://supreme.justia.com/cases/federal/us/239/394/) said the zoning prohibits making bricks, but doesn't prohibit collecting the clay, so this one's not a taking. (OK, fair.)


In [*Pennsylvania Coal v. Mahon* 260 U.S. 393 (1922)](https://supreme.justia.com/cases/federal/us/260/393/), ([Wikipedia article](https://en.wikipedia.org/wiki/Pennsylvania_Coal_Co._v._Mahon)) the Supreme Court ruled that the Kohler Act not allowing some types of coal mining is a taking. (Coal property rendered worthless.)


In fact, *Pennsylvania Coal* is often used as an example of police power regulations that "go too far"—when the Kohler Act regulates far less than prohibition.




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In *Euclid v. Ambler* ([*Village of Euclid, Ohio v. Ambler Realty Co.*, 272 U.S. 365 (1926)](https://en.wikipedia.org/wiki/Village_of_Euclid_v._Ambler_Realty_Co.), the Court ruled that a property split between multiple zoning districts, though now impossible to develop, is a valid use of police power. (Value reduced significantly.)


[*Nectow v. Cambridge* 277 U.S. 183 (1928)](https://en.wikipedia.org/wiki/Nectow_v._City_of_Cambridge) said that a *re*-zoning of a property and interfering with its sale is a deprivation of property and NOT a valid use of police power. (Value reduced to zero for one sale.)




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Are these considered reversals? There are more examples of the Supreme Court going back and forth on these issues. Why does the Court do this?



Is Nectow (1928) a reversal of Euclid (1926)? Is Pennsylvania Coal (1922) a reversal of Mugler (1887)?