The Highway Beautification Act of 1965, 23 U.S.C. §131(d) limits the erection of signs within the act's provisions solely to areas zoned for commercial or industrial purposes and no case was found allowing a property owner to replace a nonconforming billboard after it was lawfully removed from the property.
Billboards Divinity, LLC v. Commissioner of Transportation
Connecticut Appellate Court
February 16, 2012