Euclid. Today most local governments in the United States have zoning ordinances. Lambert v. Yellowley In Lambert v. Yellowley, 272 U.S. 581 (1926), the Supreme Court reaffirmed the National Prohibition Act's limitation on the dispensation of alcoholic medicines. The Court affirmed dismissal of a suit in which New York City physician Samuel Lambert sought to prevent Edward Yellowley, the acting federal prohibition director, from enforcing the Prohibition Act so as to preclude Lambert from prescribing alcoholic medicines. The decision strengthened the police powers of the individual states, and clarified the Necessary and Proper Clause of the United States Constitution, which was cited in upholding the Prohibition Act's limitations as a necessary and proper implementation of the Eighteenth Amendment to the United States Constitution. Citation style Under the Judiciary Act of 1789 the federal court structure at the time comprised District Courts, which had general trial jurisdiction; Circuit Courts, which had mixed trial and appellate (from the US District Courts) jurisdiction; and the United States Supreme Court, which had appellate jurisdiction over the federal District and Circuit courts—and for certain issues over state courts. The Supreme Court also had limited original jurisdiction (i.e., in which cases could be filed directly with the Supreme Court without first having been heard by a lower federal or state court). There were one or more federal District Courts and/or Circuit Courts in each state, territory, or other geographical region. The Judiciary Act of 1891 created the United States Courts of Appeals and reassigned the jurisdiction of most routine appeals from the district and circuit courts to these appellate courts. The Act created nine new courts that were originally known as the "United States Circuit Courts of Appeals." The new courts had jurisdiction over most appeals of lower court decisions. The Supreme Court could review either legal issues that a court of appeals certified or decisions of court of appeals by writ of certiorari. On January 1, 1912, the effective date of the Judicial Code of 1911, the old Circuit Courts were abolished, with their remaining trial court jurisdiction transferred to the U.S. District Courts. Bluebook citation style is used for case names, citations, and jurisdictions. "# Cir." = United States Court of Appeals e.g., "3d Cir." = United States Court of Appeals for the Third Circuit "D." = United States District Court for the District of . . . e.g.,"D. Mass." = United States District