Congress has full power to create territorial governments and to give to them any or all of the general powers of governments, including the power of creating private corporations. All corporate charters granted by territorial governments, however, are subject to amendment or repeal by Congress.

"Territorial governments occupy towards Congress something of the same relation as municipalities - such as city governments - fill towards the State legislatures. A State legislature can repeal the charter of a municipal government and the ordinances passed under it, so Congress can repeal the organic act of a territory and all territorial enactments in pursuance of the organic act. Congress is the sovereign power to legislate for the territories, and all charters from territorial legislatures must be held to have been accepted with the knowledge that Congress possessed the authority to change or repeal the law creating them."2