The court’s decision in Santa Clara v. Southern Pacific (1886) had been a victory for the railroads since it embraced the idea of corporate personhood. In Santa Clara the Supreme Court had, without discussion or argument, ruled that in regard to the assessment of taxes the equal protection clause applied to corporations in California. The decision itself, however, said nothing about the status of corporations as persons. That came in a preface to the decision by the court reporter, and it did not articulate what personhood might involve.
