The theory of state preeminence over local governments was called the "Dillon Rule" in an 1868 case: "Municipal corporations owe their origin to, and derive their powers and rights wholly from, the legislature. It breathes into them the breath of life, without which they cannot exist. As it creates, so may it destroy. If it may destroy, it may abridge and control." "Clinton v Cedar Rapids and the Missouri River Railroad",(24 Iowa 455; 1868). As opposed to the Dillon Rule, the Cooley Doctrine expressed the theory of an inherent right to local self-determination. In a concurring opinion, Michigan Supreme Court Judge Thomas M. Cooley in 1871 stated: “[L]ocal government is a matter of absolute right; and the state cannot take it away.” "People v. Hurlbut", (24 Mich 44, 95; 1871).