Abstract
It is argued in this paper that structural theories of local powers are inadequate as determinate explanations of urban form. This argument is developed through an interpretation of two jurisdictional disputes, one in Chicago, the other in Toronto. The legal bases of local powers are considered as are the languages and decision logic used by the courts in these two situations. At one level, the issue is one of the virtue or otherwise of the underlying political philosophy; especially liberalism. But, at another level, the issue is one of agency; the courts' capacities to fashion determinate interpretations of the proper scope of local power.

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