courts give the Legislature free rein over the state’s various types of special districts, including: school, irrigation, reclamation, drainage, bridge and highway districts, and redevelopment agencies. Special districts are always agencies of the State. As such, their creation and attributes are wholly in the Legislature’s discretion.”) (emphasis added). 31 . Chicago, B. & Q. Ry. Co. v. Illinois, 200 U.S. 561, 26 S.Ct. 341, 349, 50 L.Ed. 596 (1906) (emphasis added). 32 . See, e.g., Medtronic, Inc. v. Lohr, 518 U.S. 470, 475, 116 S.Ct. 2240, 135 L.Ed.2d 700 (1996) (“Throughout our history the several States have exercised their police powers to protect the health and safety of their citizens.”). 33 . See, e.g., Chao v. Hospital Staffing Servs., Inc., 270 F.3d 374, 378 (6th Cir.2001) (<HOLDING>); Corporacion de Servicios Medicos
holding single coexecutors release of mortgage debt paid to estate was valid and binding on estate because acts of any coexecutor in respect to the administration of the effects of the estate are deemed to be the acts of all as where one releases a debt or settles an account of a person with the deceased or surrenders a term or sells the goods and chattels of the estate his act binds the others characterizing conversion of decedents personal property into cash as act in due course of administration of estate holding that bank as coexecutor of estate breached its fiduciary and statutory duties to creditor when it failed to pay creditors claim against estate and instead paid claims of bank and other creditors holding that the secretary of labors suit is not in furtherance of her statutory powers to regulate and enforce labor standards but rather is designed to and would if allowed to proceed promote the private rights of unpaid workers visavis other creditors of the debt ors estate holding that private rights of action to enforce federal law must be created by congress courts may not create a cause of action absent statutory intent holding creditors lacked standing to file an adversary action asserting the interests of the estate in seeking to prevent a former principal of the debtor from interfering with the chapter 11 reorganization given the lack of showing of the debtors consent and any determination by the bankruptcy court that the suit would be beneficial to the estate and necessary to a fair and efficient resolution of the bankruptcy proceedings