In the 1950s, city planners working with the U.S. Congress decided that Southwest should undergo a significant urban renewal — in this case, meaning that the city would declare eminent domain over all land south of the National Mall and north of the Anacostia River (except Fort McNair); evict virtually all of its residents and businesses; destroy all streets, buildings, and landscapes; and start again from scratch. The seizure of the entire area, including well maintained properties, was upheld by the United States Supreme Court in "Berman v. Parker". Justice William Douglas emphasized the squalor and segregation the area suffered, noting that the area was 98% black while 58% of dwellings had outside toilets.