In its 1926 opinion in Village of Euclid, Ohio v. Ambler Realty, 272 U.S. 365 (1926), the U.S. Supreme Court upheld what is known today as Euclidean zoning—use-based zoning districts regulating residential and nonresidential uses together with area and bulk standards. At issue in Village of Euclid was the exercise of the police power. Were the land use regulations reasonable? Did they evince a substantial relation to the public health, safety, morals, or general welfare?