Aaron Montgomery Ward, who is known both as the inventor of mail order and the protector of Grant Park, twice sued the city of Chicago to force it to remove buildings and structures from Grant Park and to keep it from building new ones.[19][20] In 1890, arguing that Michigan Avenue property owners held easements on the park land, Ward commenced legal actions to keep the park free of new buildings. In 1900, the Illinois Supreme Court concluded that all landfill east of Michigan Avenue was subject to dedications and easements.[21] In 1909, when he sought to prevent the construction of the Field Museum of Natural History in the center of the park, the courts affirmed his arguments.[22][23] As a result, the city has what are termed the Montgomery Ward height restrictions on buildings and structures in Grant Park; structures over 40 feet (12 m) tall are not allowed in the park, with the exception of bandshells.[24] Therefore, the theater is mostly underground,[25] while the adjacent Jay Pritzker Pavilion was described as a work of art to dodge the height restriction.[26]
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