The Supreme Court limited the amount of protection granted to corporate charters under the contracts clause.
Rhode Island granted a bank charter to Providence Bank in 1791 and in 1822 sought to impose a tax on the capital stock of all banks including Providence, which claimed it was exempt because no tax was included in its charter. Providence claimed protection under the contracts clause of Article I of the Constitution, but the Supreme Court, by a 7-0 vote, held that the contracts clause protected only explicit contractual commitments. In his opinion for the Court, Chief Justice John Marshall
Charles River Bridge v. Warren Bridge