With no constitutional authority to do so, Congress created a separate form of government for the District of Columbia.

With the passage of  “District of Columbia Organic Act of 1871” a city state or what you would call a state within a state was formed. This state was called the District of Columbia and was about 10 square miles and changed the world (see, Acts of the Forty-first Congress,” Section 34, Session III, chapters 61 and 62).  

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