A major change occurred on May 1, 1870, when the City of Alexandria was excluded from the County. This came about through the implementation of an Act of the Assembly[49] following the adoption of a new Virginia Constitution in 1869. In delineating the magisterial districts into which counties were to be divided it was provided that "no part of any town or city having a separate organization, or a population of five thousand or more inhabitants, shall be embraced." Alexandria was such a city and thereafter was independent of as well as outside of the County. [49] Acts of Assembly, 1869-70, Chapter 39. [Illustration: MAP IV Areas Annexed by the City of Alexandria in 1915 and 1929 Drafted by W. B. Allison and B. Sims] There were no further legislative changes in the boundaries of the City of Alexandria after 1871. In 1915, however, the Supreme Court of Appeals of Virginia, reversed a decision of the Circuit Court of Alexandria County given on January 13, 1913. The City Council of Alexandria had sought to annex adjoining territory from both Fairfax and Alexandria counties and had been opposed by the authorities of those counties who had been upheld by the Circuit Court. The Order of the Supreme Court of Appeals[50] transferred 866 acres from Arlington and 450 acres from Fairfax to Alexandria. [50] Alexandria County, _Deed Book 146_, p. 387. See Appendix. Cf. also, C. B. Rose, Jr., "Annexation of a Portion of Arlington County by the City of Alexandria in 1915," _The Arlington Historical Magazine_, pp. 22-36, Vol. 2, No. 4 (1964). For a discussion of the judicial process of annexation, cf. Bain, _Annexation in Virginia_. This annexation took effect on April 1, 1915. Once more thereafter Arlington County--as it became known after 1920[51]--was to lose territory to the City of Alexandria. This was in 1929 when a decision of the Supreme Court of Appeals[52] rendered May 4, 1929, found in favor of the City of Alexandria which had begun annexation proceedings in December 1927. [51] Acts of Assembly, 1920, Chapter 241. [52] Arlington County, _Common Law Order Book 12_, p. 293. Also, _Deed Book 306_, p. 300. The Court held that "it is necessary and expedient that the corporate limits of the City of Alexandria should be extended" and that "the territory to be annexed from Arlington County is a reasonably compact body of land and contains no land which is not adapted to city improvement, and the Court being also of the opinion that no land is included which the City will not need in the reasonably near future for development ..." The Court ordered the annexation[53] to take effect on December 31, 1929. The line thus established remained in effect until January 1, 1966. [53] See Appendix.