City of El Paso v. Simmons (1964)
- Docket
- 38
- Decided
- 1964-01-01
- Category
- General
Summary
Question: Did the 1941 amendment to the Texas law violate the Contract Clause of the Constitution? Conclusion: While the Court agreed that the power of a state to modify the obligation of a contract is not limitless, it found that the 1941 amendment was not offensive to the Contract Clause. Justice White reasoned that the amendment was enacted with the intent of restoring "confidence in the stability and integrity of land titles" and to rectify difficulties that mineral speculators were creating for the state as it attempted to implement its land sale program. White argued that the five-year limit provided "purchasers with a bona fide interest in their lands" plenty of time to rescue their property while it served an important state interest of encouraging defaulting purchasers to comply with their contractual obligations to Texas.