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authorities cannot constitutionally be outlawed by zoning without paying the owner. C. Zoning as a Means of Restricting Noncompatible Uses. [[underlined]] Under the United States Constitution and the Constitutions of all the States, there is recognized in government a "police power" which may be exercised in the interest of the public as a whole, for its welfare, without the need to compensate individuals for financial losses they may suffer as a result of its exercise. The theory is that each member of the public is compensated for his loss by his share of the public benefit. Traffic rules are a simple, everyday example of the exercise of the police power. It may cost a New Yorker hundreds of dollars a year to park his car in a garage near his office because parking on the streets is banned, but he of course has no right to compensation because the parking limitations are a valid exercise of the police power. It was not until 1926 that the United States Supreme Court specifically upheld a zoning ordinance as a valid exercise of the police power. /109 Until that time efforts to restrict various areas to certain types of use (i.e., limiting obnoxious industry to a particular area) had been regarded as invasions of the rights of the owners of the property in question to use their property as they saw fit