Abstract
Efforts to prohibit apartments, rather than merely regulate their construction and condition, began in the 1890s. Through the early 1920s, major cities used stringent building codes to achieve this goal. During this era housing experts played a leading role in nurturing the ideology that multifamily housing was an evil. In the 1910s and 1920s, municipalities introduced single family-only zoning to curb apartment construction. State supreme courts split over whether such regulations were constitutionally justified by public safety and welfare considerations.

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