California's dirty laundry: the roots of modern zoning

A discussion of Chapter 5 of Yoni Appelbaum’s “Stuck”

We’re discussing Yoni Appelbaum’s Stuck: How the Privileged and the Propertied Broke the Engine of American Opportunity. Each week, I’ll dive into a chapter, connecting the national story to what I see locally. There are 10 chapters—we’re halfway through! Join me in the comments with your own observations about mobility, housing, and community in your area.

Previous chapter discussion here ↔ next chapter here.

This week: Chapter 5, “Dirty Laundry.”

“A street in San Francisco’s Chinatown, ca. 1900. The first zoning laws in the U.S. were adopted by California cities in the late 19th century to exclude Chinese residents.” Arnold Genthe/Heritage Art/Heritage Images/Getty Images

With this chapter, Appelbaum’s argument shifts from “history professor” to something more visceral as he documents, unrelentingly, how American zoning laws emerged from late 19th and early 20th-century policies designed to exclude Chinese immigrants from California communities. It shows how those exclusionary impulses evolved into the “facially neutral” zoning laws that continue to segregate American communities today.

If you read no other chapter of this book, please read this one. I found it so fascinating—by which I mean, I stomped around very angrily as I listened. (The benefit of audiobooks: you can do something with your body if the words make you mad.) Earlier chapters were interesting, but this one explains so much about California … and Los Alamos, Santa Fe, and other exclusionary cities.

What I learned

Before reading this, I thought zoning mostly started in 1926 with the Supreme Court case Euclid v. Ambler. Turns out, the roots go back decades earlier. Modesto’s 1885 ordinance banning laundries from anywhere but Chinatown didn’t mention race—but everyone understood what it was about.

For centuries, land use was governed by nuisance law and the broad “police powers” of local governments. Two principles guided it:

• Sic utere tuo: use your property however you want, so long as it doesn’t injure others.

• Salus populi: government can regulate to protect health, safety, and welfare.

That framework handled slaughterhouses, tanneries, fire hazards, and the like. If a land usage was actually dangerous, the city could regulate it. What a city could not do was arbitrarily declare a perfectly safe use (like a laundry) a “nuisance” simply because Chinese immigrants owned it.

Modesto’s ordinance created a precedent: The same activity could be perfectly legal in one part of town, yet illegal in another, based not on safety but on who your neighbors were. To put it another way: if Modesto had truly been concerned with how safe laundries were, they would not have mandated that laundries only be allowed in residentially denser parts of town.

This was the birth of zoning.

“The Chinese Must Go, But Who Keeps Them?” – May 1878 by George Frederick Keller for The San Francisco Illustrated Wasp. See the context here.

How to make racism “facially neutral”

This history set the template for modern exclusionary zoning. Cities learned a neat trick: they could achieve segregation without naming race! They could ban entire categories of business—laundries, dance halls, boarding houses—without saying “Chinese” or “Black.”

Some 30 years after Modesto’s restrictions on the locations of laundries, the city of Berkeley, under the influence of the architect Charles H. Cheney (who fretted a great deal about “the intrusion of the less desirable and floating renter class”), passed the first zoning ordinance that made everything other than single-family dwellings illegal in significant swaths of the city. The Berkeley ordinance also introduced the “innovation” of complex and convoluted categorizations (e.g., five classes of residential dwellings) to American zoning codes. As Applebaum writes:

The men who were central to the effort to pass Berkeley’s zoning ordinance, after all, openly boasted of its racist roots. “The fight against the Chinese wash-house laid the basis for districting laws in this state,” one wrote. “We are ahead of most states in our court decisions, thanks to the persistent proclivity of the ‘heathen Chinese’ to clean garments in our midst,” said another. Zoning, argued a third, was a permanent solution to the scourge of laundries. The city had allowed one laundry to operate in a residential area, and, he alleged, it “deteriorated that neighborhood until only negros and Orientals would rent the nearby buildings.”

The strategy was cynical but brilliant: mask racist exclusion under legalistic land-use categories. Appelbaum puts it like this: “If Modesto’s law had a thoroughly modern ring, it was precisely because its formula—masking the language of exclusion in the arid prose of land-use law—would prove to be remarkably enduring.”

This worked because courts, while unwilling to uphold outright racial bans, were willing to accept “neutral” rules about what kinds of buildings could go where.

And once you invent a tool this powerful—controlling land uses to control who gets to live there—it doesn’t stay confined to laundries! It expands. Cheney, in Berkeley, used the same tool in 1913 not to target laundries, but to ban apartments altogether (emphasis below is mine):

When [Cheney] recommended extending the boundaries of the new residential zone to encompass the street fronts that face the neighborhood, he failed to say that from the front porch of his beautiful Arts and Crafts-style home, he looked out on the houses lining the northern side of Russell Street to which he was extending protection. To put it plainly, single-family zoning was invented by a particularly determined and talented NIMBY, to prevent anyone from building apartments nearby.

Services, but not service providers

American communities want services, but not the service providers. Chinese laundries were wildly popular because they filled a real need. But white people didn’t want to live next to Chinese neighbors.

That contradiction has not gone away. In Los Alamos, people speak openly about not wanting service workers to live near them. But even people with advanced degrees are increasingly seen as unwanted. I regularly hear retirees complain that LANL should stop hiring or set up satellite campuses far away. Because suddenly the whole reason the town exists stops mattering the moment you retire, I guess? The same issue has played out in Berkeley (emphasis mine):

Rising enrollment at the university increased demand, but growing numbers of students and other renters were forced to commute from Oakland or Alameda. Over the following decades, development resumed, but demand was channeled away from Berkeley’s verdant neighborhoods of single-family homes. By 1950, the population neared 114,000, and there it effectively stagnated, restrained by law from further growth despite mounting demand. In 2021 the census estimated the population at 117,000.

Yeah. We want the economic engine. We want the services. But heaven forbid we allow the people providing them to actually live nearby.

I don’t want to hammer too much on the guy who wrote the letter to the editor that I shared in a previous post, but basically, he said, “I don’t want my housekeeper as my neighbor.” He is not alone! I hear, verbally, similar sentiments from people clever enough not to put it in writing. These notions are an echo of Modesto’s: Those people can live somewhere else.

We’ll take your labor, but we won’t share a community.

New and creative ways to say “keep out”

Appelbaum details cases like Quong Wo and Hang Kie, Chinese laundry operators who challenged these laws in what were, in effect, early civil rights cases. Neighbors testified their laundries weren’t a nuisance at all. But they lost anyway, because the point wasn’t public safety. It was territorial control.

That impulse, to wall off “our” land from outsiders, is pretty deep in our DNA. You can see it throughout human history, not just in the United States (obviously, but worth saying). But I don’t mean this to sound glib or fatalistic. Appelbaum makes it clear that the Modesto flavor of exclusion, this new-in-its-time “zoning law” that is racist without mentioning race, wasn’t inevitable. Existing law would have blocked it. White Californians had to invent new, more restrictive legal tools to make their exclusion stick.

A Puck cartoon from 1882 depicts an ethnically diverse team of American laborers uniting to construct a wall against Chinese labor, labeled with blocks such as prejudice, fear, non-reciprocity, using “Congressional mortar.” In the background, Chinese workers dismantle their own Great Wall, welcoming trade. The image satirizes how U.S. policy erected barriers to exclude Chinese immigrants even as China opened its doors. Wikimedia commons

Local parallels

I don’t think most people here consciously connect zoning with race; they aren’t saying, “we want to exclude people based on skin color.” But when I hear residents describe our town as a tiny, sweet little town that must be reserved for special people, I do think of Berkeley homeowners clutching their garden city pearls against the supposed “threat” of apartments. When Santa Feans say any building taller than the St. Francis Cathedral is a weed, I hear the same slippery-slope panic that Appelbaum documents from California’s problematic history.

So maybe our exclusionary zoning today is grounded less in explicit racism than in generalized xenophobia, classism, or just plain fear of change. But roots and branches are connected; you can’t separate one from the other. And like Berkeley, we’ve lived the consequences. Los Alamos capped itself at roughly 8,000 homes decades ago, and the population has barely budged since. It’s not that people don’t want to live here—it’s that zoning has kept them out. Berkeley’s story is the same: the population flatlined after 1950 despite a booming university. Housing prices shot up, economic segregation became more entrenched, and demand was simply shunted to neighboring towns. The lucky and the wealthy got a house. Everyone else got to commute.

In Berkeley, the consequences are that nearly one-third of neighborhoods are concentrated white wealth zones with scant low-income households, and affordable housing remains chronically underbuilt. But unlike Los Alamos, Berkeley responded with a middle-housing ordinance to legalize duplexes and triplexes. Zoning reform in Berkeley is slow, but it’s happening. In Los Alamos, attempts at reform have been far more timid. (A story for another day.)

Every community thinks they’re the specialist community. But every community with human beings in it, and a job center, has a tension between needing more rooftops for workers and wanting to exclude anyone new or different.

The persistence and varieties of exclusion

Appelbaum makes the point that eliminating zoning won’t fix this: not by itself. Suppose you upzone to allow more residential variety (a good idea!) but your land-use law still separates residential from commercial uses—you can still exclude, y’know, laundries. That’s why minimum lot sizes, parking mandates, and bans on useful little businesses matter so much. “Single-family zoning didn’t create America’s housing problems by itself, and simply rolling it back cannot fix them,” he writes.

One of the most striking things about this chapter is how much of this history we’ve forgotten. Anti-Black and anti-Latino racism remain part of the national conversation, as they should. But the virulent anti-Chinese sentiment that drove early zoning has almost vanished from historical memory. Asian Americans are now held up as the “model minority” (which is itself quite problematic), but a century ago, entire legal systems were designed to push them out.

If you want to dig deeper into this fraught history, and fiction is more your thing, I recommend a few novels: Peach Blossom Spring by my friend (and fellow Los Alamos High School grad!) Melissa Fu; Interior Chinatown by Charles Yu; and The Four Treasures of the Sky by Jenny Tinghui Zhang. These novels bring to life different pieces of the Chinese American experience. These are some that I read and loved—please, readers, suggest more!

What is done can be undone

This chapter gave me context for why we’re stuck (get it, stuck) with zoning systems that continue to segregate communities today. The exclusionary tools pioneered against Chinese laundries didn’t disappear when racial language became unacceptable. They evolved into “facially neutral” zoning that excludes by class instead.

That’s the lesson I’ll carry: our housing crisis isn’t natural. It’s not a byproduct of economics or running out of land. It’s the result of deliberate legal tools invented to keep certain people out of certain places.

Which means it can be undone by different tools, different choices.

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Reader responses from Chapter 4

Ted Swing shared how Appelbaum’s chapter connected to his family’s mobility story. His parents moved from rural Minnesota to a small town, then to a medium-sized city where he grew up. After grad school in the midwest, he moved to Phoenix—and his parents and brother followed. “Moving in this way has enabled upward economic mobility,” he said. Ted also reflected on how his family’s frequent moves may have shaped their openness to immigrants, and connected his Swedish great-grandparents’ emigration to America to escape limited land opportunities—a problem he sees returning to the U.S. today.

Andie from The Good Enough Newsletter initially struggled with Appelbaum’s premise that mobility drives American dynamism, but the “Moving Day” description won her over—she imagined the camaraderie of moving into a neighborhood simultaneously with others. She distinguished between Appelbaum’s two mobility waves: first, the westward movement toward farmsteads where families like Abraham Lincoln’s achieved self-sufficiency through land ownership, and second, the later urban migration that resembles today’s moves for established job markets rather than raw opportunity. Andie wondered whether our mobility has slowed because technological improvements have plateaued—we have air conditioning, running water, and instant communication, so “maybe we just can only get marginally better from here on out and our next task is to find ways to share the bounty more equally.”

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Next week: Chapter 6, “Tenementophobia”—how fear of dense housing became embedded in American law and culture.

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Discussion questions for Chapter 5:

• What examples do you see of rhetoric that sounds like safety concerns but might really be about exclusion?

• How might your community differ if mixed-income housing (say, shops with flats above) had been built continuously rather than banned for decades?

• How do we distinguish between reasonable density limits and exclusionary policies disguised as planning?