Everything about Santa Clara County V Southern Pacific Railroad totally explained
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 what it did
not hold, but was later misunderstood to have held--namely, 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 didn't base its decision on this issue. However, before
oral argument took place,
Chief Justice Morrison R. Waite announced: "The court doesn't 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 wasn't in the opinion itself. As such, it didn't have any legal precedential value. Nonetheless, the persuasive value of Waite's statement did influence later courts. For these reasons, it's considered a turning point in the extension of constitutional rights to juristic persons.
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