Santa Clara County V. Southern Pacific Railroad - Decision

Decision

The court's actual decision was uncontroversial. A unanimous decision, written by Justice Harlan, ruled on the matter of fences, holding that the state of California illegally included the fences running beside the tracks in its assessment of the total value of the railroad's property. As a result, the county could not collect taxes from Southern Pacific that it was not allowed to collect in the first place.

Thus the Supreme Court's actual decision never hinged on the equal protection claims. Nevertheless, the case has been allowed to have clear constitutional consequences, as it has been subsequently taken to affirm the protection of corporations under the Fourteenth Amendment. At the very least, this is a wrinkle in the normal understanding of the workings of the Court's tradition of stare decisis - the reliance on precedence. It is an instance in which a statement which is neither part of the ruling of the Court, nor part of the opinion of a majority or dissenting minority of the Court has been taken as precedent for subsequent decisions of the Court.

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