How a municipality refers to itself has been said to be a decision that is up to the community. The Massachusetts Supreme Judicial Court has ruled that what a municipality calls itself doesn't matter: "It is the substance of the thing done, and not the name given to it, which controls". Opinion of the Justices to the Senate, 229 Mass. 600 (Mass. 1918). The "City known as the Town of" reference was intended in communities adopting it to assert its right to exercise the authority of a city in governance, municipal finance and procurement. In the early days of the spread of the council-based municipal government to towns, it served to eliminate confusion as to a town's ability to do a particular thing.