In City of Savannah v. Martin, the Supreme Court of the United States was asked to decide whether a city ordinance that prohibited the sale of alcoholic beverages within the city limits was constitutional. The ordinance was challenged by Martin, who argued that it violated the Fourteenth Amendment's Equal Protection Clause. The Court held that the ordinance was constitutional, finding that the city had a legitimate interest in protecting the health and safety of its citizens. The Court noted that the ordinance was not overly broad and did not discriminate against any particular class of people. Furthermore, the Court found that the ordinance was not an unreasonable exercise of the city's police power. In conclusion, the Court held that the ordinance was constitutional and did not violate the Equal Protection Clause of the Fourteenth Amendment. The Court's decision was unanimous.

Justice Field delivered the dissenting opinion in City of Savannah v. Martin, arguing that the majority's decision was a misinterpretation of Georgia law and an infringement on state sovereignty. He argued that under Georgia law, when a city charter is amended to increase its debt limit, it must be done through legislative action rather than by referendum as had been done in this case. Furthermore, he argued that while Congress has authority over territories and states admitted after 1789 (when the Constitution was ratified), it does not have authority over those states already existing at ratification without their consent; thus Congress could not pass laws which would interfere with or supersede state legislation regarding municipal corporations such as cities like Savannah. Therefore Justice Field concluded that since no act of Congress authorized Savannah to increase its debt limit via referendum instead of legislative action, the amendment should be declared void and unconstitutional.