The Obligation of Contracts Clause of the United States Constitution

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Another close case is that of Illinois Central R. Co. v. Illinois, 79 where it was held that the State could not make irrevocable grant of land covered by navigable waters, if it will substantially impair the public interest in the lands and waters remaining.
"Owenstooro v. Cumberland Telephone Co., 230 U. S. 58; Old Colony Trust Co. v. Omaha, 230 U. S. 100; Boise Water Co. v. Boise City, 230 U. S. 84.
™ U. S. 387.
110 OBLIGATION OF CONTRACTS [654 It remains to review the proceedings of the Con
...stitutional Convention of 1787, of the State conventions, and the other historical data concerning the adoption of the " contracts clause." Justice Miller, in his lectures on the Constitution has said: _ It has seemed probable to many judges and lawyers who have con- sidered this clause of the Constitution that it was not' designed by the framers of that instrument to do anything more than protect private contracts, those between individuals and those between indi- viduals and private corporations, that is, not municipal corporations, but those organized for purposes of profit; and if it were now an original question, it is by no means certain but that this would be held to be the sound view of it.

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