Fisher v. City of New Orleans

Background

Teachers and others sued to force New Orleans to levy a special tax of one and one-half mills to pay contracts made with the School Board in 1874–1876 under Louisiana’s Act of 1873. They asked a court order to compel the city to raise the extra tax. The Louisiana Supreme Court denied that relief, finding the claimants had delayed too long and that the 1873 law did not let the School Board bind the city to levy more than the council’s chosen amount. The plaintiffs then sought review in the United States Supreme Court.

Reasoning

The central question was whether the U.S. Supreme Court had authority to overturn the state decision on the ground that a later state constitution or law impaired the contracts. Justice Holmes explained that federal review applies when a state judgment gives effect to a later law that impairs contracts. Here the state court concluded either no binding contract existed or the claimants had lost rights through long delay (laches). Holmes also summarized the 1873 Act, showing the City Council had to levy only a minimum school tax and was not required to match the School Board’s full estimates.

Real world impact

Because the state court did not rely on a later law that impaired contractual obligations, the U.S. Supreme Court dismissed the case for lack of federal jurisdiction and left the state court’s denial in place. Claimants therefore cannot force New Orleans to raise the extra tax for those years, and the long delay in bringing the petition (filed in 1907) was a significant obstacle. The ruling does not decide the constitutionality of later state laws; it limits federal review when the state court finds no enforceable contract.