Note 1626 — ARTICLE I (continued 6)

In Munn v. Illinois, 94 U.S. 113 (1877) a category of "business affected with a public interest" and whose property is "impressed with a public use" was recognized. A corporation engaged in such a business becomes a "quasi-public" corporation, the power of the State to regulate which is larger than in the case of a purely private corporation. Inasmuch as most corporations receiving public franchises are of this character, the final result of Munn v. Illinois was to enlarge the police power of the State in the case of the most important beneficiaries of the Dartmouth College decision.