In New Jersey v. Wilson (1812) 11 U.S. 164, the Supreme Court held that a State could properly grant a permanent tax exemption and that the Contract Clause prohibited any impairment of such an agreement. This holding has never been repudiated, although tax exemption contracts generally have not received a sympathetic construction. (See B. Wright, The Contract Clause of the Constitution 179-194 (1938)).That case supports the Treaty and Act constituting a contract between the State of New Jersey and those Indians who took up residence on the Brotherton Reservation. Besides establishing the reservation and precluding the Indians from making future sales or leases of their interests in the reservation land, the Act also provided that the reservation land would be exempt from tax. The Court in Wilson considered whether the Act constituted a contract and whether the contract was violated by a subsequent Act by the New Jersey Legislature in 1804, which repealed the tax exemption. In considering these questions, the Court noted that "every requisite to the formation of a contract is found in the proceedings between the then colony of New Jersey and the Indians," and concluded that "this is certainly a contract clothed in forms of unusual solemnity." (Ibid.)