People can express their political or social views in gardens, intentionally or not. The lawn vs. garden issue is played out in urban planning as the debate over the "land ethic" that is to determine urban land use and whether hyper hygienist bylaws (e.g. weed control) should apply, or whether land should generally be allowed to exist in its natural wild state. In a famous Canadian Charter of Rights case, "Sandra Bell vs. City of Toronto", 1997, the right to cultivate all native species, even most varieties deemed noxious or allergenic, was upheld as part of the right of free expression.