The Wall Street Journal had an interesting story last week on how city governments are clashing with state governements over controversial policies. Subject matter includes smoking bans, plastic bags, transgender bathrooms and sanctuary cities.

But the story omits one important fact. Legally, cities are corporate creatures of the states. States are sovereign; corporations are not. Municipal and private corporations were often, two centuries ago, each created by specific acts of state legislatures. But in the nineteenth century, states passed laws allowing cities and private organizations to incorporate under general incorporation laws. In addition, in the early twentieth century, many states passed “home rule” laws, granting incorporated cities certain rights of self-government.