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revitalization, and ultimately social progress, could be achieved by beautification and sanitation regimes with attention to landscape design, municipal improvement and civic configuration, also captured some of Howard's ideas.45 The most noteworthy of Howard's ideas to be embraced by American civic planners, which was also in many ways the culmination of the City Beautiful movement, was the adoption of segregated uses and the preference for single family homes.46 Inspired by Howard's ideas, and in response to concerns with building uniformity, public health, safety and welfare, starting in the late 1800s in the United States, cities and towns began to develop zoning codes.47 Zoning has been hailed as the single most important innovation promoted by American planners in the years prior to World War I.48 In 1926, the legality of zoning was established in Village of Euclid v. Ambler Realty.49 In Euclid, Ambler Realty Company, which owned land in the Village of Euclid, Ohio, situated just outside of Cleveland, Ohio, sought to enjoin the Village of Euclid from enforcing a comprehensive zoning ordinance. Euclid's zoning ordinance rendered one portion of Ambler's tract useable for only single or two family homes, another portion for single or two family homes 45 William H. Wilson, The Ideology, Aesthetics and Politics of the City Beautiful Movement, in The Rise of Modern Urban Planning, 1800-1914 165, 166 (Anthony Sutcliffe ed., 1980). � Peterson supra note 14, at 308. 47 Id. at 308-309. � Id. at 308 49 272 U.S. 365 (1926). For a broad discussion of the Euclid case and of Euclidean zoning in general, see Richard Chused, Symposium On The Seventy-Fifth Anniversary Of Village Of Euclid v. Ambler Realty Co.: Euclid's Historical Imagery, 51 Case W. Res. 597 (2001). 15