387 Tonawanda v. Lyon, 181 U.S. 389 (1901) Cass Farm Co. v. Detroit, 181 U.S. 396 (1901). Rather, the reason of the modification was to increase to the citizens of the states the very same defense towards arbitrary point out laws impacting existence, liberty, and house as was afforded versus Congress by the Fifth Amendment. 487 (1882) (non-public reason bonds not licensed by condition structure).