The validity of zoning was established in a landmark Supreme Court decision in 1926, Euclid v. Ambler Realty Co.,3 in which it was determined that the exclusionary nature of zoning was appropriate and in the public interest as a means to reduce nuisances, and as such overrides the interests of individual property owners. This case almost by itself guaranteed the validity of zoning as a rightful use of the state's police power, and led to its importance as the most significant tool of land use, and of planning, yet devised. And it was popular not because of its sophistication, but because of its simplicity. The 1926 Supreme Court case upheld that land use could be controlled, and that "nuisance" uses could be kept out of designated areas.