In Rolston v. Missouri Fund Commissioners, the Supreme Court of the United States was asked to decide whether the Missouri Fund Commissioners had the authority to issue bonds to fund the construction of a railroad. The Court held that the Commissioners did not have the authority to issue the bonds, as the state legislature had not authorized them to do so. The case arose when the Missouri Fund Commissioners issued bonds to fund the construction of a railroad. The bonds were issued without the authorization of the state legislature, and the bondholders sued the Commissioners for payment. The Commissioners argued that they had the authority to issue the bonds under the state constitution. The Supreme Court disagreed, holding that the Commissioners did not have the authority to issue the bonds. The Court reasoned that the state constitution did not grant the Commissioners the power to issue bonds, and that the state legislature had not authorized them to do so. The Court also noted that the state legislature had the exclusive power to issue bonds, and that the Commissioners had exceeded their authority in issuing the bonds. The Court's decision in Rolston v. Missouri Fund Commissioners established that the state legislature has the exclusive power to issue bonds, and that the state's executive branch cannot issue bonds without the legislature's authorization. This decision has been cited in numerous subsequent cases involving the issuance of bonds by state governments.

Justice Field delivered the dissenting opinion in Rolston v. Missouri Fund Commissioners, arguing that the majority's decision was contrary to established precedent and would have a detrimental effect on state governments' ability to manage their finances. He argued that states should be allowed to issue bonds with terms of repayment which are different from those specified by the original bondholders, as long as they do not violate any constitutional provisions or laws passed by Congress. In this case, he argued that Missouri had acted within its rights when it issued new bonds with longer terms of repayment than those originally agreed upon by the bondholders. Furthermore, Justice Field noted that if states were unable to modify their debt obligations in such cases then they would be forced into bankruptcy more often than necessary and could potentially face economic ruin due to an inability to borrow money for public works projects or other essential services.