Zoning and deed restrictions are the major legal Instruments employed for land use decisions in the U.S. The land use patterns of Dallas, a zoned city with stated public goals of "health, safety and welfare" and that of non-zoned Houston with laissez-faire attitudes and an active private enterprise (with deed restrictions as a major legal instrument) have more similarities than differences. One of the major reasons for such similarities Is the American ideal of free-hold land tenure established when the nation was founded and epitomized by the single family detached housing unit. The principles of "right to private property", laid down by philosophers like Blackstone, Smith and Locke, have subsequently been maintained and strengthened by legal, fiscal and social doctrines. This American lore (ownership of single family detached residence) and the "laws" (land use laws that support and further the "ideal") suggests that this social ideal has taken the form of "natural law" in the American society, sometimes with unexpected consequences.