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The thought for a new town midway between Baltimore, Maryland and Washington, D.C. Columbia, Maryland, the deliberate growth of The Rouse Company of Baltimore, Maryland, is one in all the finest examples of a contractual neighborhood within the United States. Justice George Sutherland, who delivered the majority opinion, believed that the exclusion of buildings devoted to business from residentially zoned areas bore "a rational relation to the well being and safety of the neighborhood." The problem with this justification is that "the well being and safety of the community" is as open-ended a concept as "the overall welfare." Sutherland justified the exclusion of businesses from residential areas on the grounds that there could be much less visitors, kids and pedestrians can be safer, that there could be less disorder, and that municipal fireplace and police safety would be made easier and less costly to supply. Supreme Court Justice Oliver Wendell Holmes summed up the statist view of the police power in two different cases. During the first two a long time of the 20th Century, business and professional teams had been instrumental in bringing about local zoning ordinances. Other architects, metropolis planners, engineers, and real estate males all believed within the desirability and "necessity to carry some order out of the chaos that has resulted from the anarchistic improvement of our cities." Such groups as the National Association of Real Estate Boards, the Chamber of Commerce of the United States, the American Society of Civil Engineers, the American Society of Landscape Architects, and the National Housing Association all banded together to push zoning.

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