Under Virginia law, the only municipalities that may be contained within counties are incorporated towns; incorporated cities are independent of any county. Arlington, despite its population density and largely urban character, is wholly unincorporated with no towns inside its borders. In the 1920s, a group of citizens petitioned the state courts to incorporate the Clarendon neighborhood as a town, but this was rejected; the Supreme Court of Virginia held, in "Bennett v. Garrett" (1922), that Arlington constituted a "continuous, contiguous, and homogeneous community" that should not be subdivided through incorporation.