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zoning established in Euclid v. Ambler Realty Co.' and applied by the California Supreme Court in Associated Home Builders etc., Inc. v. City of Livermore.° The land use ordinance position has been most clearly adopted by the New Jersey Supreme Court, in Southern Burlington County NAACP v. Township of Mount Laurel.? The court rejected distinctions between socioeconomic and other zoning, noting that all zoning, such as that for "detached single family residential zones, high-rise multi-family zones of any kind, ... indeed[,] practically any significant kind of zoning" has inherent socioeconomic characteristics. The court held that, where a community's obligation to provide housing for all income groups could not be met by the removal of zoning restrictions, "inclusionary devices such as ... mandatory set-asides keyed to the construction of lower income housing, are constitutional and within the zoning power of a municipality...We know of no governmental purpose ... that is served by requiring a municipality to ingeniously design detailed land use regulations ... actually aimed at accommodating lower income families, while not allowing it directly to require developers to construct lower income units."8 In 1990, in Holmdel Builders Ass'n v. Township of Holmdel,9 the New Jersey Supreme Court revisited the issue while reviewing the constitutionality of affordable housing fees required by several New Jersey cities. The court explained that "inclusionary-zoning devices," including inclusionary in-lieu fees, are land use ordinances that bear a "real and substantial relationship to the regulation of land" because they are specifically designed to help create affordable housing 5 272 U.S. 365 (1926). 6 18 Ca1.3d 582,604-05 (1976). 7 456 A.2d 390(N.J. 1983). R Id. at 448-50. 9 583 A.2d 277(N.J. 1990) 3 990051 A I A720372.3 8/7/2009