In 1934 the Supreme Court banned the dumping of municipal waste into the ocean, which had become very common up to this time. Shortly after the U.S. engaged in warfare and the rest of the country made efforts to clean up by recycling rubber, paper, scrap metal, and tin cans (25% of waste stream). Around 1945 100 cities in the U.S. were using sanitary landfills. After the war, open burning dumps and backyard waste burning was prohibited in most areas. Consumerism reaches an unbelievable high due to the ease of plastics, and America has been named the “throwaway society.” The amount of packaging produced and disposed of increases 67% after World War II.