Southern Pacific Railroad

Santa Clara County v. Southern Pacific Railroad

Santa Clara County v. Southern Pacific Railroad Company, was a United States Supreme Court case dealing with taxation of railroad properties. The case is most notable for the obiter dictum statement that juristic persons are entitled to protection under the Fourteenth Amendment.

For its opinion, the Court consolidated three separate cases: Santa Clara County v. Southern Pacific Railroad Company, California v. Central Pacific Railroad Company, and California v. Southern Pacific Railroad Company.

California had created a law which provided for taxation of railroad property. The taxpaying railroads challenged this law. They raised numerous defenses, including claims that the taxes violated equal protection. The lower court had entered judgment for the railroads, holding that the tax assessments were void because they improperly included property which was outside the jurisdiction of the agency that assessed the tax.

The Supreme Court never reached the equal protection claims. Nonetheless, this case is sometimes incorrectly cited as holding that corporations, as juristic persons, are protected by the Fourteenth Amendment. Although the question of whether corporations were persons within the meaning of the Fourteenth Amendment had been argued in the lower courts and briefed for the Supreme Court, the Court did not base its decision on this issue. However, before oral argument took place, Chief Justice Morrison R. Waite announced: "The court does not wish to hear argument on the question whether the provision in the Fourteenth Amendment to the Constitution, which forbids a State to deny to any person within its jurisdiction the equal protection of the laws, applies to these corporations. We are all of the opinion that it does. This quotation was printed by the court reporter in the syllabus and case history above the opinion, but was not in the opinion itself. As such, it did not have any legal precedential value. Nonetheless, the persuasive value of Waite's essentially ultra vires statement did influence later courts, becoming part of American corporate law without ever actually being enacted by statute or formal judicial decision. For these reasons, it is literally an unprecedented extension of constitutional rights to US corporations.

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