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Santa Clara County V. Southern Pacific Railroad




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.Santa Clara County v. Southern P. R. Co., 118 U.S. 394 (U.S. 1886) (Lexis-Nexis summary)

The Supreme Court never reached the equal protection claims. Nonetheless, this case is sometimes incorrectly cited as holding that corporations, as 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."118 U.S. 394 (1886) - According to the official court Syllabus in the United States Reports 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.Thomas Van Flein. "Headnotes and the Course of History." The Alaska Bar Rag. May/June, 2003 (27 AK Bar Rag 2) Nonetheless, the persuasive value of Waite's statement did influence later courts.Shepard's summary for 118 U.S. 394 For these reasons, it is considered a turning point in the extension of constitutional rights to juristic persons. {Link without Title}


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