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This US Supreme Court case involved the Board of Liquidation of the City Debt of New Orleans and the Louisville and Nashville Railroad Company. The Board of Liquidation sought to recover a debt from the Railroad Company, which had been incurred by the City of New Orleans in the construction of a railroad. The Railroad Company argued that the debt was barred by the statute of limitations. The Supreme Court held that the statute of limitations did not apply in this case, as the debt was not a personal debt, but rather a debt of the City of New Orleans. The Court further held that the City of New Orleans was not bound by the statute of limitations, as it was not a party to the contract between the Railroad Company and the City. The Court concluded that the debt was still valid and enforceable, and the Board of Liquidation was entitled to recover the debt from the Railroad Company.
In Board of Liquidation of the City Debt of New Orleans v. Louisville and Nashville Railroad Company and Another, Justice Field delivered a dissenting opinion in which he argued that the majority’s decision was contrary to established precedent. He noted that it had long been held by this Court that when an act is passed for public purposes, such as providing funds for municipal debt relief, any private interests must be incidental to those public purposes in order for the act to be valid. In this case, however, he believed there were clear indications that some portions of the Act were intended solely for private benefit rather than general welfare; thus making them unconstitutional under existing law. Furthermore, Field argued that even if these provisions could somehow be construed as having a legitimate purpose related to public welfare they should still have been struck down because they violated other constitutional principles such as due process or equal protection under law. Ultimately Justice Field concluded his dissent by noting his disagreement with the majority’s ruling and expressing hope “that no further legislation will ever again pass our legislature containing similar features."