In January 2001, the New York Appellate Division, First Department in "Fisher v. Giuliani", partially upheld the 1998 expansion of the Theater Subdistrict zoning regulations, which added receiving sites along Eighth Avenue where development rights from the landmarked Broadway theaters could be sold. Community and civic organizations opposed the expansion of the district as it would impinge the nearby residential neighborhood of Hell's Kitchen/Clinton. The court objection, filed in 1999, did not challenge the pre-existing Theater Subdistrict itself or the original development rights zoning legislation.