In the case of Tyrrell, Administratrix of Tyrrell v. District of Columbia (1916), the U.S Supreme Court ruled in favor of the District of Columbia. The plaintiff, Mrs. Tyrrell, was seeking compensation for her husband's death caused by a defective street pavement which resulted in an accident while he was riding his bicycle. However, according to common law principles and statutory provisions at that time, municipalities were not liable for injuries sustained due to negligence or misfeasance related to public improvements such as streets unless there is a specific statute imposing liability on them. Therefore, despite acknowledging that Mr.Tyrrell’s death may have been due to negligent maintenance by the city authorities; it held that no legal claim could be made against them under existing laws.

In the dissenting opinion for Tyrrell v. District of Columbia, Justice Holmes disagreed with the majority's decision that a statute of limitations could not be applied retroactively to bar a claim. He argued that there was no constitutional prohibition against such an application and noted that it had been done in other cases without issue. Furthermore, he contended that allowing this claim would open up the possibility for countless others which could have serious financial implications on municipalities like D.C., potentially leading to bankruptcy or insolvency due to unforeseen liabilities from years past. Thus, he believed it was necessary and prudent for legislatures to have the ability to limit these potential claims through statutes of limitation.