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John Forrest Dillon (1831-1914) was an American jurist who served on both federal and Iowa state courts during his lengthy career.[iii] In 1872, while sitting on what would later become the Court of Appeals for the Eighth Circuit, he published an influential extended essay or treatise on the power of states over municipal governments, entitled Municipal Corporations, or, later, The Law of Municipal Corporations. Dillon argued, quite persuasively it seems, that municipal governments can operate only within the express powers given them by their state governments