Contract Clause
In the early case of Holmes v. Jennison,[2] Chief Justice Taney, referencing the Contract Clause, wrote an opinion which found that states had no power under it to honor an extradition request from a foreign government.Speaking for a unanimous Court, Chief Justice Hughes declared: “When its action does not conflict with federal legislation, the sovereign authority of the State over the conduct of its citizens upon the high seas is analogous to the sovereign authority of the United States over its citizens in like circumstances.”[5] In constitutional context, "bills of credit" mean paper medium of exchange intended to circulate between individuals, and between the Government and individuals, for the ordinary social purposes.[16] A law that prohibited any person convicted of a felony and not subsequently pardoned from holding office in a waterfront union was not a bill of attainder because the “distinguishing feature of a bill of attainder is the substitution of a legislative for a judicial determination of guilt” and the prohibition “embodies no further implications of appellant’s guilt than are contained in his 1920 judicial conviction.”[17] The Framers of the Constitution added this clause in response to the fear that states would continue a practice that had been widespread under the Articles of Confederation—that of granting "private relief."In Home Building & Loan Association v. Blaisdell,[19] the Supreme Court upheld a Minnesota law that temporarily restricted the ability of mortgage holders to foreclose.[22][21] The Supreme Court laid out a three-part test for whether a law conforms with the Contract Clause in Energy Reserves Group v. Kansas Power & Light.[21] In United States Trust Co. v. New Jersey,[25] the Supreme Court held that a higher level of scrutiny was needed for situations where laws modified the government's own contractual obligations.