an income tax. Other cases History has taken little notice of most of Jackson's remaining opinions. He was assigned to write a number of opinions involving patent law, a field with which his circuit court tenure had given him experience. A disproportionate number of his rulings drew no dissents, suggesting they were mostly insignificant. His poor health and the fact that he was one of the newest justices for the entirety of his brief tenure likely contributed to this. Jackson's few cases display support for the proposition that the judiciary should defer to the legislature. His opinions in Schurz v. Cook (1893) and Columbus Southern Railway v. Wright (1894) rejected attempts by corporations to strike down various tax laws. Jackson's opinions also evidence both his support for broad federal power and his skepticism of states' decisions. In Mobile & Ohio R.R. v. Tennessee (1894), he favored a broad interpretation of the Contract Clause, ruling over four dissenting votes that Tennessee acted illegally in using its state constitution to renege on a promised tax exemption for a railroad company. In the 1893 case of Brass v. North Dakota, meanwhile, he exhibited support for the concept of substantive due process, joining a dissent by Justice Brewer that argued that a North Dakota regulation of grain elevators was an unconstitutional infringement upon the freedom of contract. Finally, he joined a five-justice majority in Fong Yue Ting v. United States (1893) to hold the federal government could deport Chinese immigrant laborers without providing them with due process protections. Illness and death Despite being apparently healthy at the time of his nomination, Jackson developed tuberculosis within a year of taking the bench. He returned quickly to his duties, but his illness worsened, and he had to leave the capital. In October 1894, he journeyed to the West hoping the climate would improve his condition. He traveled to Thomasville, Georgia, a few months later; his lung ailment started improving, but his health deteriorated substantially when he was afflicted with dropsy. Having no independent source of income, Jackson could not retire without a special act of Congress giving him a pension. Being too unwell to participate, he was unable to cast a vote in the consequential cases of United States v. E. C. Knight Co. and In re Debs. Jackson returned to his Tennessee home in February; his health began improving, and he expressed the hope that