of Pittsburgh, despite the objections of a majority of Allegheny's residents. The Court's ruling that states could alter or abolish at will the charters of municipal corporations without infringing upon contract rights relied upon Dillon's distinction between public, municipal corporations and private ones. However, the Court did not prevent states from passing legislation or amending their constitutions to explicitly allow home rule. This constitutional allowance was reiterated in Trenton v. New Jersey, where the Supreme Court held that "In the absence of state constitutional provisions safeguarding it to them, municipalities have no inherent right of self-government which is beyond the legislative control of the state, but are merely departments of the state, with powers and privileges such as the state has seen fit to grant, held and exercised subject to its sovereign will”. Hundreds of United States court decisions have employed the Dillon Rule to determine the scope of municipal powers and rights. Critics of the rule have argued that it imposes unreasonable constraints on the ability of communities to govern themselves and undermines democracy or that local self-government is a matter of natural right that does not need to be conferred by higher political structures. Some have suggested that Dillon's approach derived from the contemporary view that cities were inherently corrupt political organs. States which do not follow Dillon's Rule—home rule states, including Dillon's own Iowa—remain in the minority, despite the significant decrease in the public perception of municipal corruption. David Y. Miller argues that Dillon hit upon a central paradox defining American cities: having great political authority while having little legal legitimacy. He quotes Dillon as calling municipalities "mere tenants at will of their respective state legislatures" which could be "eliminated by the legislature with a stroke of the pen". Dillon also said that eliminating local government would be "so great a folly, and so great a wrong". References Sources Gerald E. Frug et al., Local Government Law, 3rd ed. pp. 139–158. West Publishing, 2001. See Arlington County v. White, 528 S.E.2d 706 (Va. 2000), for a modern use of the Dillon Rule to invalidate municipal action. See State v. Hutchison, 624 P.2d 1116 (Utah 1980) for an example of the minority, critical view. David Y. Miller, The Regional Governing of Metropolitan America, pp. 1–2. Westview Press, 2002. Robert W. Creamer, "Stengel: His Life and Times," pp. 21–23. External links 1831 births 1914 deaths 19th-century American judges American