However, when the Supreme Court decided the 1823 case of "Green v. Biddle", Johnson wrote a separate opinion. In "Green", Johnson wrote an opinion that was part dissent, part concurrence. He concurred with the majority opinion that Kentucky's legislative act to restrict the rights of titleholders to their land was illegal but once again, as in "Fletcher" (1810), Johnson believed that the illegality of the act was due to its violation of general principles of law, and not due to it violating the Contract Clause. He forwent analyzing the Contract Clause as he felt it was unnecessary to the legal question in the case. "Green v. Biddle" was one of the Court's most important Contract Clause cases of the era, further expanding the clause to include public agreements such as the Virginia-Kentucky compact of 1792.