Santa Clara County v. Southern Pacific Railroad Co
"Santa Clara County v. Southern Pacific Railroad Co." is a significant Supreme Court case that addressed the taxation of railroad property in California. While the ruling itself was relatively straightforward—determining that railroad fences could not be taxed under state law—the case gained greater constitutional importance through Chief Justice Morrison R. Waite's commentary. In his opinion, Waite asserted that the equal protection clause of the Fourteenth Amendment applied not only to individuals but also to corporations. This interpretation extended the application of constitutional protections to corporate entities, setting a precedent that influenced future legal interpretations. The case is often viewed as a foundational moment for the protection of economic rights under the doctrine of substantive due process. As such, it has implications for understanding the relationship between government regulation and corporate interests in the United States. Overall, "Santa Clara County v. Southern Pacific Railroad Co." stands as a pivotal case in shaping legal considerations surrounding corporate personhood and economic liberties.
Santa Clara County v. Southern Pacific Railroad Co.
Date: May 10, 1886
Citation: 118 U.S. 394
Issue: Corporations
Significance: The Supreme Court announced that corporations were “persons” within the meaning of the Fourteenth Amendment.
In a relatively unimportant ruling, the Supreme Court unanimously decided that the fences on railroad property could not be taxed under California law. However, the case was of constitutional importance because of Chief Justice Morrison R. Waite’s statement, without argument, that the equal protection clause of the Fourteenth Amendment applied to corporations as well as to natural persons. The idea logically extended to the due process clause. Waite’s statement helped lay the foundation for the court’s later protection of economic liberties under the doctrine of substantive due process.
![Grosse Building, home of the Southern Pacific Railroad Company, ca.1908. By Not given [Public domain], via Wikimedia Commons 95330309-92445.jpg](https://imageserver.ebscohost.com/img/embimages/ers/sp/embedded/95330309-92445.jpg?ephost1=dGJyMNHX8kSepq84xNvgOLCmsE2epq5Srqa4SK6WxWXS)
![The Old Courthouse of Santa Clara County, CA. By DavidMCEddy (Own work) [CC-BY-SA-3.0 (http://creativecommons.org/licenses/by-sa/3.0)], via Wikimedia Commons 95330309-92486.jpg](https://imageserver.ebscohost.com/img/embimages/ers/sp/embedded/95330309-92486.jpg?ephost1=dGJyMNHX8kSepq84xNvgOLCmsE2epq5Srqa4SK6WxWXS)