This was reversed by the New York Supreme Court, Appellate Division, which found that control or regulation of population growth did not fall under the authorized uses of zoning.

Writing for the court, Justice John F. Scileppi stated, "The restrictions conform to the community's considered land use policies as expressed in its comprehensive plan and represent a bona fide effort to maximize population density consistent with orderly growth.

[4] The New York Court of Appeals returned to this issue 20 years later in Long Island Pine Barrens Society, Inc. v. Planning Board of Brookhaven, where the appellate division required a cumulative environmental impact analysis over three towns for developments, which was seen as a threat to local land use authority.

The Court of Appeals overturned the appellate division, disappointing environmentalists who had seen an opportunity for cumulative analysis for critical natural resource areas around the state.

[5] Golden v. Ramapo and Construction Industry Association of Sonoma County v. The City of Petaluma, California are the basis for the use of development impact fees to finance public infrastructure throughout the United States.