Nuisance: "Nuisance is traditionally used to describe an activity which is harmful or annoying to others such as indecent conduct or a rubbish heap. Nuisances either affect private individuals (private nuisance) or the general public (public nuisance). The claimant can sue for most acts that interfere with their use and enjoyment of their land. In English law, whether activity was an illegal nuisance depended upon the area and whether the activity was "for the benefit of the commonwealth", with richer areas subject to a greater expectation of cleanliness and quiet. The case Jones v Powell (1629) provides an early example, in which a person's professional papers were damaged by the vapors of a neighboring brewery. Although the outcome of this case is unclear, Whitelocke of the Court of the King's Bench is recorded as saying that since the water supply in area was already contaminated, the nuisance was not actionable as it is "better that they should be spoiled than that the commonwealth stand in need of good liquor". In Rylands v. Fletcher (1868), strict liability was established for a dangerous escape of some hazard, including water, fire, or animals as long as the cause was not remote. In this case, chemicals from a factory seeped through a floor into the water table, contaminating East Anglia's water reservoirs. Free market environmentalists would like to expand tort damage claims into pollution (example-toxic torts) and environmental protection