Santa Clara County v. Southern Pacific Railroad…

Santa Clara County v. Southern Pacific Railroad Company, 118 U.S. 394 (1886) is a matter brought before the United States Supreme Court—but not decided by the court—which deals with taxation of railroad properties.

A report issued by the Court Reporter claims to state the sense of the Court—without a decision or written opinions published by or of the Court.

This is the first time that the Supreme Court is reported to hold that the Fourteenth Amendment equal protection clause grant constitutional protections to corporations as well as to natural persons, although numerous other cases, since Dartmouth College v. Woodward in 1819, have recognized that corporations sre entitled to some of the protections of the Constitution.

In his dissent in the 1938 case of Connecticut General Life Insurance Company v. Johnson, Justice Hugo Black will write "in 1886, this Court in the case of Santa Clara County v. Southern Pacific Railroad, decided for the first time that the word 'person' in the amendment did in some instances include corporations. [...] The history of the amendment proves that the people were told that its purpose was to protect weak and helpless human beings and were not told that it was intended to remove corporations in any fashion from the control of state governments. [...] The language of the amendment itself does not support the theory that it was passed for the benefit of corporations." (Connecticut General Life Insurance Company v. Johnson 303 U.S. 77, 87 (1938), (Black, J. dissenting).)

Justice William O. Douglas will write in 1949, "the Santa Clara case becomes one of the most momentous of all our decisions. [...] Corporations were now armed with constitutional prerogatives." (Douglas, William O. (1949), "Stare Decisis", Columbia Law Review 49 (6): 735–758, doi:10.2307/1119147.)