Troy Ltd. v. Renna, 727 F.2d 287 (1984)

Citation: Troy Ltd. v. Renna, 727 F.2d 287 (1984)
Parent Document: Troy Ltd. v. Renna, 727 F.2d 287 (1984)
Jurisdiction: United States (federal)
Effective Date: 1984-01-30
Original Source: https://www.courtlistener.com/opinion/431015/troy-ltd-v-renna/ ↗

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Although the contract clause arose from the purported repudiation of contracts between private parties, the Supreme Court held in 1810 that the clause prohibited a state's repudiation of its own contracts as well. Fletcher v. Peck, 10 U.S. (6 Cranch) 87, 137-39, 3 L.Ed. 162 (1810). Fidelity to the principle that "one legislature cannot abridge the powers of a succeeding legislature," id. at 134, 3 L.Ed. 162, soon, however, led to a relaxation of the rigor with which the Court scrutinized legislation decreasing the value of public contracts. See, e.g., Charles River Bridge v. Warren Bridge, 36 U.S. (11 Pet.) 420, 432, 9 L.Ed. 773 (1837) (charter to operate a bridge subject to legislative power to charter a competitor); Stone v. Mississippi, 101 U.S. 814, 817-20, 25 L.Ed. 1079 (1880) (state-chartered lottery company rendered valueless by subsequent abolition of lotteries); Fertilizing Co. v. Hyde Park, 97 U.S. 659, 667-70, 24 L.Ed. 1036 (1878) (value of state-chartered fertilizer company impaired by ordinance prohibiting transportation of fertilizer).

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