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Campbell v. District of Columbia was a United States Supreme Court case that dealt with the issue of whether the District of Columbia had the authority to impose a tax on the income of non-residents. The case was brought by a resident of the District of Columbia, who argued that the tax was unconstitutional. The Supreme Court held that the District of Columbia did not have the authority to impose the tax, as it was not authorized by Congress. The Court reasoned that the District of Columbia was not a state, and therefore did not have the same powers as a state. The Court also noted that the tax was not authorized by the Constitution, and that it was an unconstitutional burden on non-residents. The Court concluded that the tax was invalid and could not be enforced.
In Campbell v. District of Columbia, the Supreme Court was asked to decide whether a statute passed by Congress that allowed for the payment of damages to individuals who had been wrongfully arrested and imprisoned in Washington D.C., applied retroactively or only prospectively. The majority opinion held that it did not apply retroactively, but Justice Field dissented from this decision on the basis that there is no language in the statute which would indicate an intent to limit its application solely to future arrests and imprisonments. He argued further that if Congress intended such a limitation they would have included specific language indicating as much within the text of the law itself, rather than leaving it open for interpretation by courts at some later date. As such he concluded that since nothing indicated otherwise, then logically one must assume Congress meant for their act to be applicable both retrospectively and prospectively; thus allowing those who had already suffered wrongful arrest and imprisonment prior to its passage access to compensation under its terms as well.