In Russell v. Sebastian, 233 U.S. 195, 58 L. Ed. 912, 34 S. Ct. 517 (1914), the Supreme Court addressed the effect of a California constitutional provision that granted private parties the "privilege of using the public streets" to lay pipes necessary to supply light and water to municipalities that lacked public works for those purposes. Id. at 198. The Court held that the provision was an offer that, when accepted by establishment of a private plant devoted to public service, "constituted a contract, and vested in the accepting individual or corporation a property right," which was protected from impairment by the contract clause in the federal constitution. Id. at 204, 210.