U.S. Supreme Court
Mattingly v. District of Columbia, 97 U.S. 687 (1878)
Mattingly v. District of Columbia
97 U.S. 687
1. Congress, in exercising legislation over property and persons within the District of Columbia, may, provided no intervening rights are thereby impaired, confirm the proceedings of an officer in the District, or of a subordinate municipality, or other authority therein, which, without such confirmation, would be void.
2. An Act of Congress approved June 19, 1878, 20 Stat. 166, entitled "An Act to provide for the revision and correction of assessments for special improvements in the District of Columbia, and for other purposes," considered, with reference to the preceding legislation of Congress and of the legislative assembly of said District. Held, 1. that said act was practically a confirmation of the doings of the board of public works of the District, touching the improvement of streets and roads and a ratification of the assessments prepared under an Act of said assembly of Aug. 10, 1871, as charges upon the adjoining property, and that it conferred authority upon the commissioners to revise and correct such assessments within thirty days after the passage of the act; 2. that such confirmation was as binding and effectual as if authority had been originally conferred by law to direct the improvements and make the assessments.
The facts are sufficiently stated in the opinion of the Court.