Santa Clara County v. Southern Pacific Railroad Company, 118 U.S. 394; 6 S. Ct. 1132; 30 L. Ed. 118 (1886)
Facts—California brought action against the Southern Pacific and other railroad companies for taxes and interest on taxes assessed on their property within the state. A U.S. Circuit Court had voided these taxes.
Significantly, as a relatively early interpretation of the Fourteenth Amendment, this case focused on the protection of property rights rather than on discrimination based on race. In the briefs, counsel for the railroads argued that “Corporations are persons within the meaning of the Fourteenth Amendment to the Constitution of the United States.” According to Court records, prior to the oral argument, C.J. Waite announced that the Court would not consider the question “whether the provision in the Fourteenth Amendment to the Constitution which forbade a state to deny to any person within its jurisdiction the equal protection of the Constitution, applied to these corporations. We are all of the opinion that it does.”
Question—(a) Are corporations considered to be persons under the Fourteenth Amendment? (b) Did California’s taxation of railroad property violate the equal protection of law under the Fourteenth Amendment?
Decision—(a) Yes; (b) Yes.
Reasons—J. Harlan (9–0). The Court argued that the commission that assessed taxes on the railroad grouped such property with surrounding fences and other property that the commission had no legal authority to assess. The assessments were not separable and therefore constituted a denial of equal protection of the laws. The railroads were not liable for the taxes.