In the 1891 case of Doon Township v. Cummins, the U.S Supreme Court was tasked with determining whether a township in Iowa could be held liable for damages caused by a defective bridge it had built and maintained. The plaintiff, Cummins, sustained injuries when his wagon fell through said bridge. He sued the township for negligence in its construction and maintenance of the structure. However, under Iowa law at that time, townships were not considered legal entities capable of being sued unless specifically allowed by statute. The court ruled in favor of Doon Township based on this principle: while municipalities can be held responsible for their actions or omissions as corporations acting within their corporate capacity (such as maintaining public utilities), they are immune from liability when performing governmental functions delegated to them by state law (like building roads). As such, since constructing and maintaining bridges was viewed as a governmental function rather than a corporate one under Iowa law during that period; henceforth making Doon Township immune from lawsuits related to those activities.

The dissenting opinion in the case of Doon Township v. Cummins argued that the majority's decision to uphold a tax levy for railroad bonds was incorrect. The dissenting justices believed that the township had not legally authorized these bonds, and therefore they should not be held responsible for paying them back through taxation. They contended that there were irregularities in how the vote on issuing these bonds was conducted, including allegations of fraud and bribery which cast doubt on its legitimacy. Furthermore, they pointed out inconsistencies between state law and local ordinances regarding bond issuance procedures which further complicated matters. Ultimately, they felt it unjust to burden taxpayers with this debt when there were so many questions surrounding its legality and fairness.