Santa Clara County v. Southern Pacific Railroad Co. facts for kids
Quick facts for kids Santa Clara County v. Southern Pacific Railroad |
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| Argued January 26–29, 1886 Decided May 10, 1886 |
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| Full case name | Santa Clara County v. Southern Pacific Railroad Company |
| Citations | 118 U.S. 394 (more)
6 S. Ct. 1132; 30 L. Ed. 118; 1886 U.S. LEXIS 1942
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| Prior history | Error to the Circuit Court of the United States for the District of California |
| Holding | |
| The railroad corporations are "persons" within the intended meaning of the Fourteenth Amendment to the U.S. Constitution (per headnote only). | |
| Court membership | |
| Case opinions | |
| Majority | Harlan, joined by unanimous |
| Laws applied | |
| 14 Stat. 292, §§ 1, 2, 3, 11, 18 (an Act of 1866 giving special privileges to the Atlantic and Pacific Railway Corporation) | |
Santa Clara County v. Southern Pacific Railroad Company was an important case decided by the U.S. Supreme Court in 1886. It was about how railroad companies should be taxed. The case is famous because of a special note, called a headnote, which said that companies should have the same rights as people under the Fourteenth Amendment of the U.S. Constitution. This part of the Constitution is called the Equal Protection Clause, and it means everyone should be treated fairly by the law.
Before this case, the Supreme Court had already said that companies had some rights under the Constitution. In this case, the Court sided with the railroads. However, the main opinion written by Justice John Marshall Harlan did not actually talk about the Equal Protection Clause. Instead, the special note written by the Court's official Reporter of Decisions, and approved by Chief Justice Morrison Waite, said that all the judges believed the Equal Protection Clause applied to companies. This was the first time the Supreme Court clearly suggested that companies, not just individuals, were protected by this part of the Constitution.
Contents
Why the Case Happened: Tax Trouble for Railroads
In 1878 and 1879, the state of California created a new state constitution. This new rule made it harder for railroads to pay their taxes. It said that railroads could not subtract their debts, like mortgages, from the value of their property when calculating taxes. Regular people, however, could still do this.
The Southern Pacific Railroad Company and other railroads did not want to pay these new taxes. They argued that a federal law from 1866 gave them special rights that conflicted with California's new tax rules.
Counties Sue for Unpaid Taxes
Because the railroads refused to pay, counties like San Mateo County and Santa Clara County lost a lot of tax money. They decided to sue the railroads to get the money they believed they were owed.
The California Supreme Court first heard a similar case, San Mateo County v. Southern Pacific Railroad Company, and sided with the county. Later, the U.S. Supreme Court combined three different cases into one big decision. These cases were Santa Clara County v. Southern Pacific Railroad Company, California v. Central Pacific Railroad Company, and California v. Southern Pacific Railroad Company.
The Famous Headnote: Are Companies "Persons"?
The most famous part of this case is not what the judges officially decided, but a note written by the Reporter of Decisions, J.C. Bancroft Davis. A headnote is like a summary of the case. It is written by the Reporter, not the judges, to help lawyers understand the decision.
Davis, who used to be the president of a railway company, wrote this in the headnote:
One of the points made and discussed at length in the brief of counsel for defendants in error was that 'corporations are persons within the meaning of the Fourteenth Amendment to the Constitution of the United States.' Before argument, Mr. Chief Justice Waite said: 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 means that before the lawyers even started arguing the case, Chief Justice Waite said that all the judges already believed that the Fourteenth Amendment's "equal protection" rule applied to companies. However, the official decision of the Court did not actually discuss this point.
How the Headnote Became Important
Before the case was officially published, Davis wrote to Chief Justice Waite to make sure his headnote was correct. Waite replied that Davis's note accurately described what was said. He also told Davis to decide if the note should be included, since the Court did not officially rule on that question.
A historian named C. Peter Magrath later found these letters. He said that if Davis had left out that note, the Santa Clara County case might have been forgotten. It would have just been another tax case. But because of the headnote, it became a very important case in legal history. It showed what the Court was thinking, even if they did not put it in their official ruling.
What the Court Actually Decided
The Supreme Court's decision was unanimous, meaning all the judges agreed. Justice John Marshall Harlan wrote the main opinion. The Court ruled in favor of the railroads, but not because of the Fourteenth Amendment.
Instead, the Court focused on a smaller detail: fences. California had included the value of fences next to the railroad tracks when calculating the railroad's taxes. The Court said this was wrong. Fences were not part of the "roadway" that the state could tax. Because the state had illegally included the fences, the county could not collect those taxes.
So, the big question of whether companies were "persons" under the Equal Protection Clause was never officially decided in the Court's ruling. The case was won on a technicality about fences.
Why This Case Matters Today
Even though the Supreme Court's official decision did not talk about the Equal Protection Clause, the Santa Clara case has had a huge impact. The headnote, which was just a summary by the Reporter, has been used as a precedent in many later cases. This means that courts have often cited it as proof that the Fourteenth Amendment protects companies.
This is unusual because a headnote is not an official ruling or opinion from the judges. Yet, it has been treated as if it were.
Justice Hugo Black disagreed with this idea in 1938. He wrote that the Fourteenth Amendment was created to protect "weak and helpless human beings." He believed it was not meant to give special rights to companies.
Justice William O. Douglas also commented on the case in 1949. He said that because of the Santa Clara case, "Corporations were now armed with constitutional prerogatives." This means companies gained powerful constitutional rights.
