In the 1911 case of New York Continental Jewell Filtration Company v. District of Columbia, the Supreme Court was asked to determine whether a contract between the filtration company and Washington D.C. was legally binding or not. The city had contracted with the company for water purification services but later sought to terminate this agreement on grounds that it violated anti-monopoly laws and exceeded authorized expenditures for such contracts set by Congress. The court ruled in favor of New York Continental Jewell Filtration Company, stating that while some aspects of their contract may have been illegal under federal law, it did not invalidate the entire agreement because these elements were severable from its lawful parts. Furthermore, they held that since Congress had approved an appropriation bill which included funds for this specific contract after its execution, they implicitly ratified any potential excesses over statutory limits on spending.

The dissenting opinion in the case of New York Continental Jewell Filtration Company v. District of Columbia argued that the city was not liable for damages because it had acted within its rights and responsibilities to protect public health. The justice believed that the contract between the company and city did not guarantee uninterrupted work, but rather allowed for necessary interruptions due to unforeseen circumstances or emergencies such as a cholera outbreak. Therefore, when an epidemic threatened public health, it was reasonable and lawful for the city to halt construction on a water filtration system until conditions were safe again. This interruption did not constitute a breach of contract by the District of Columbia nor should they be held financially responsible since their actions were motivated by protecting citizens' welfare during an emergency situation.