The Supreme Court expanded the contracts clause to include public as well as private contracts.
The 1792 Virginia-Kentucky compact stipulated that Kentucky land titles were to be decided by the preexisting Virginia laws, which protected a number of absentee landowners. However, Kentucky passed a law allowing its settlers to recover the value of improvements they made on land they occupied even if they were not the owners under Virginia law. Virginia objected and took the case to the Supreme Court. In his 1821 opinion for the Court, Justice Joseph Story
Contract, freedom of