In a discussion of the heifer ritual when a murder victim is found between two cities, Sotah 9:2 lists some cases when a city does not bring a heifer, including a city where a majority of the inhabitants are not Jewish and a city where there is no court. The city without a court must be a Jewish-majority one, else there would be no need to mention it here because it would already be covered by the previous case. But that, in turn, got me wondering how a Jewish city could possibly not have a court. It says עיר (city), so I assume the mishna is not talking about a tiny village that doesn't have three learned men.
At the time of the mishna, were there enough Jewish cities without a court that the mishna had to consider the case? Or is this likely to be a theoretical case, just in case a city should be lacking a court for whatever reason?