HARVARD LAW REVIEW. VOL. V. NOVEMBER 15, 1891. No. 4. A RECENT DECISION OF THE SUPREME COURT UPON MUNICIPAL BONDS. FOR more than a third of a century, the Supreme Court of the United States, aside from questions of constitutional law, has been dealing with no single class of cases, it is safe to say, of greater moment to the growth and material prosperity of the country than controversies between the holder of a negotiable bond and the State or municipal corporation which, after the se- curity had been put upon the market in its name, has for one rea-
- son or another seen fit to deny its validity, and to refuse to pay
the indebtedness it purported to secure. The municipal coupon bond, as everybody is aware, has played a conspicuous, one may say indispensable, part in the development of our cities and towns, more especially throughout the West. Coming into use from necessity, it has proved to be an instrument singularly well adapted to take the capital of those who have saved their earnings, and to set it at work in distant localities, where needed to build railroads, bridges, court-houses, school-houses, sewers, water-works, and the like improvements that a rapidly growing community requires. A thousand-dollar bond held by a savings institution has not unfre- quently represented the aggregate savings of several depositors, whose small deposits are thus enabled to earn a good rate of inter- est. It will hardly be denied that this form of security has been a convenient, and upon the whole a safe, means of accomplishing
