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The first modern American public land use zoning restriction was enacted in San Francisco in 1867 to constrain the location of obnoxious uses. Los Angeles, in 1909, applied land use controls to an immense area it had annexed, sparking a series of lawsuits that culminated in the U.S. Supreme Court's 1915 ruling in Hadacheck v. Sebastian. The Court upheld the City's prohibition of brickyards in a residentially zoned district, despite the fact that the brickyard in question predated the residential development.
While California cities explored land use controls, in the East the focus was on control of building height, bulk, and yards. Actions to limit the height of buildings and to vary these heights by zones taken in Massachusetts were found to be constitutional by the Supreme Court in Welch v. Swasey in 1909. This was followed three years later by the Court's clearly implied approval of building setback controls in Eubank v. Richmond.
In the early decades of the 20th century, New York City was faced with construction of tall buildings that cut off light and air to the streets below and to surrounding buildings. It also experienced an invasion of manufacturing uses into areas that were predominantly residential and business in character.
In response, in 1916, New York enacted the first "comprehensive zoning code." It utilized the three geographically zoned elements that the U.S. Supreme Court previously acted on (building height, setbacks and yards, and land use) and combined them in a single ordinance that included the entire area of jurisdiction. This combination of factors still defines "comprehensive zoning."
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