 California Vehicle Code, Sections 360, 590, define a "highway" as only a way open for use of motor vehicles, but the California Supreme Court has held that "the definition of 'highway' in the Vehicle Code is used for special purposes of that act," and that canals of the Los Angeles neighborhood of Venice, California, are "highways" that are entitled to be maintained with state highway funds.Smaller roads may be termed byways.Modern highway systems developed in the 20th century as the automobile gained popularity.