"In addition to these there were a few insurance companies, a number of
companies formed for the Indian trade, numerous land companies, large
and small, a number of associations for erecting bridges, building or
repairing roads, and improving navigation of small streams or rivers.
Besides these there were a few colonial corporations not easily classed,
such as libraries, chambers of commerce, etc.

"During the Revolution few corporations of any sort were chartered.
After the conclusion of peace the situation was materially altered.
Capital had accumulated during the war. The disbanding of the army set
free a labor supply, which was rapidly increased by throngs of
immigrants. The day was one of bold experimentation, enthusiastic
exploitation of new methods, eager exploration of new paths, confident
undertaking of new enterprises. Everything conspired to bring about a
considerable extension of corporate enterprise in the field of business
before the end of the eighteenth century, notably after the critical
period of disunion and Constitution-making has passed. Prior to 1801
over three hundred charters were granted for business corporations; 90
per cent. of them after 1789. Judged by twentieth-century standards
these seem few, indeed, but neither in the colonies nor in the mother
country was there precedent for such a development." 105 The Nation 512
(New York, Nov. 8, 1917), reviewing Joseph Stancliffe Davis, Essays in
the Earlier History of American Corporations (2 vols., Harvard
University Press, 1917).

[1617] In 1806 Chief Justice Parsons of the Supreme Judicial Court of
Massachusetts, without mentioning the contracts clause, declared that
rights legally vested in a corporation cannot be "controuled or
destroyed by a subsequent statute, unless a power be reserved to the
legislature in the act of incorporation," Wales _v._ Stetson, 2 Mass.
143 (1806). _See also_ Stoughton _v._ Baker et al., 4 Mass. 522 (1808)
to like effect; _cf._ Locke _v._ Dane, 9 Mass. 360 (1812) in which it is
said that the purpose of the contracts clause was to "provide against
paper money and insolvent laws." Together these holdings add up to the
conclusion that the reliance of the Massachusetts court was on
"fundamental principles," rather than the contracts clause.

[1618] 4 Wheat., especially at 577-595 (Webster's argument); ibid. 666
(Story's opinion). _See also_ Story's opinion for the Court in Terrett
_v._ Taylor, 9 Cr. 43 (1815).

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