Santa Clara County v. Southern Pacific Railroad

Lochner EraEconomic Regulation

The case is remembered for the Court's assertion that corporations are persons under the Fourteenth Amendment, a point stated without argument.

Overview

Southern Pacific Railroad challenged county property tax assessments on fences along its rights of way. Before oral argument, Chief Justice Waite told counsel that the Court did not wish to hear argument on the equal protection clause, since the Constitution does not distinguish between natural and artificial persons. The decision itself resolved the tax matters on other grounds, but the headnote and later citations treated corporations as constitutional persons. Santa Clara became the anchor for extending Fourteenth Amendment protections to corporations, shaping a century of corporate constitutional rights doctrine.

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