Santa Clara County v. Southern Pacific Railroad

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This case is a relatively uninteresting tax case, known for neither its facts nor its holding. What makes the case significant is an offhand remark from Justice Morrison Remick Waite, made from the bench before the beginning of oral argument:

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 opinion that it does.

And thus a two-sentence comment by a single Justice elevated corporations to the status of people under the law and created the doctrine of legal personhood.

 

 Santa Clara v. Southern Pacific Railroad

 

118 U.S. 394 (1886)

ERROR TO THE CIRCUIT COURT OF THE UNITED STATES FOR THE DISTRICT OF CALIFORNIA

The defendant Corporations are persons within the intent of the clause in section 1 of the Fourteenth Amendment to the Constitution of the United States, which forbids a state to deny to any person within its jurisdiction the equal protection of the laws.

Under the Constitution and laws of California relating to taxation, fences erected upon the line between the roadway of a railroad and the land of coterminous proprietors are not part of "the roadway," to be included by the State Board in its valuation of the property of the corporation, but are "improvements" assessable by the local authorities of the proper county.

An assessment of a tax is invalid, and will not support an action for the recovery of the tax, if, being laid upon different kinds of property as a unit, it includes property not legally assessable, and if the part of the tax assessed upon the latter property cannot be separated from the other part of it.

The State Board of Equalization of California were required by law to assess the franchise, roadway &c., of all railroads operated in more than one county and apportion the same to the different counties in proportion to the number of miles of railway in each. They made such assessment of the Southern Pacific Railroad, improperly including therein the fences between the roadway and the coterminous proprietor, and apportioned it and returned it as required to the different counties. In a suit by one of the counties to recover its proportion of the tax levied in accordance with such apportionment and return, the court below at the trial found that "said fences were valued at $300 per mile," which was the only finding on the subject, and it did not appear that the county, plaintiff, offered to take judgment for a sum excluding the rate on the value of the fences within the county at that valuation. Held (1) that the finding was too vague and indefinite to serve as a basis for estimating the aggregate valuation of the fences included in the assessment, or the amount thereof apportioned to the respective counties; (2) that under the circumstances, the Court could not assume that the State Board included the fences in their assessment at the rate of $300 per mile for every mile of the railroad within the state, counting one or both sides of the roadway, and could not, after eliminating that amount from the assessment, give judgment for the balance of the tax, if any.

These actions, which were argued together, were brought to recover unpaid taxes assessed against the several railroad corporations, defendants, under the laws of the California. The main -- almost the only -- questions discussed by counsel in the elaborate arguments related to the constitutionality of the taxes. This Court, in its opinion passed by these questions and decided the cases upon the questions whether under the Constitution and laws of California, the fences on the line of the railroads should have been valued and assessed, if at all, by the local officers, or by the State Board of Equalization; whether, on the record, the assessments and taxation upon the fences are separable from the rest of the assessment and taxation, and what was the effect of the record upon the rights of the state and the county.

To read the rest of the opinion in Santa Clara County v. Southern Pacific Railroad, go to Nolos US Supreme Court Center.

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