The Supreme Court of the United States has never issued a firm opinion on whether the retrocession of the Virginia portion of the District of Columbia was constitutional. In the 1875 case of "Phillips v. Payne", the Supreme Court held that Virginia had "de facto" jurisdiction over the area returned by Congress in 1847, and dismissed the tax case brought by the plaintiff. The court, however, did not rule on the core constitutional matter of the retrocession. Writing the majority opinion, Justice Noah Swayne stated only that: