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which zoned for all white or all black blocks.59 A number of American cities followed suit.60 Though there were a number of challenges to the practice, these challenges met with mixed success.61 Finally, the practice of explicitly racial zoning was struck down in Buchanan v. Warley, 62 wherein the United States Supreme Court held that a Louisville, Kentucky ordinance requiring residential segregation based on race violated the Fourteenth Amendment of the United States Constitution. Unlike prior state court rulings that had overturned racial zoning ordinances on takings clause grounds due to those ordinances' failures to grandfather land owned prior to enactment, the Court in Buchanan ruled that the motive of the Louisville ordinance, race, was an insufficient purpose to make the law constitutionaL 63 In the aftermath of Buchanan, however, cities often sought to create legally defensible racial zoning ordinances.64 In recent decades, as obvious displays of racial bias have become not only illegal but socially unacceptable, traditional zoning schemes have eschewed explicit racial references. Nonetheless, modern zoning schemes still frequently served as tools of social exclusion, This is especially true when implemented in newer towns and suburbs where they have the effect of excluding persons based on socioeconomic status with requirements such as minimum lot sizes 59 Christopher Silver, The Racial Origins of Zoning in American Cities, in Urban Planning and the African American Community 23, 27 (June Manning Thomas & Marsha Ritzdorf eds., 1997). 60 Racial zoning was seen throughout the South in cities such as in Richmond, Virginia, Charlotte, North Carolina and Atlanta, Georgia. It was also implemented in Northern cities such as Chicago, Illinois and in the far West in some California cities. Id. at 25-28. 61 Some state court rulings overturned racial zoning ordinances on takings clause grounds due to those ordinances' failures to grandfather land owned prior to enactment. 62 245 U.S. 60 (1917). 63 Id. at 82. 64 Silver, supra at 32. :