Santa Clara County v. Southern Pacific Railroad Co.
1886 United States Supreme Court case / From Wikipedia, the free encyclopedia
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Santa Clara County v. Southern Pacific Railroad Company, 118 U.S. 394 (1886), is a corporate law case of the United States Supreme Court concerning taxation of railroad properties. The case is most notable for a headnote stating that the Equal Protection Clause of the Fourteenth Amendment grants constitutional protections to corporations.
Santa Clara County v. Southern Pacific Railroad | |
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Argued January 26–29, 1886 Decided May 10, 1886 | |
Full case name | Santa Clara County v. Southern Pacific Railroad Company |
Citations | 118 U.S. 394 (more) 6 S. Ct. 1132; 30 L. Ed. 118; 1886 U.S. LEXIS 1942 |
Case history | |
Prior | Error to the Circuit Court of the United States for the District of California |
Holding | |
The railroad corporations are "persons" within the intended meaning of the Fourteenth Amendment to the U.S. Constitution (per headnote only). | |
Court membership | |
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Case opinion | |
Majority | Harlan, joined unanimously |
Laws applied | |
14 Stat. 292, §§ 1, 2, 3, 11, 18 (an Act of 1866 giving special privileges to the Atlantic and Pacific Railway Corporation) |
The case arose when several railroads refused to follow a California state law that gave less favorable tax treatment to some assets owned by corporations as compared to assets owned by individuals. The Court's opinions in earlier cases such as Dartmouth College v. Woodward had recognized that corporations were entitled to some of the protections of the Constitution. Associate Justice John Marshall Harlan's majority opinion held for the railroads, but his opinion did not address the Equal Protection Clause. However, a headnote written by the Reporter of Decisions and approved by Chief Justice Morrison Waite stated that the Supreme Court justices unanimously believed that the Equal Protection Clause did grant constitutional protections to corporations. The headnote marked the first occasion on which the Supreme Court indicated that the Equal Protection Clause granted constitutional protections to corporations as well as to natural persons.