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. 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. 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 and the museum was built elsewhere.
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. However, within Millennium Park, the 50-foot (15 m) Crown Fountain and the 139-foot (42 m) Jay Pritzker Pavilion were exempt from the height restrictions, because they were classified as works of art and not buildings or structures. Shorter structures do not run afoul of the height restrictions. The Harris Theater, which lies between the North Pavilions, was built mostly underground to avoid the restrictions. The Northwest Pavilion, tallest of the four, is three stories high; the Northeast Pavilion is two stories, and the South Pavilions are each one story.
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