Minneapolis & St. Louis Railway v. Beckwith: Corporate Personhood Doctrine Becomes Settled Law

The Supreme Court formally declared corporate personhood as settled constitutional law, with Justice Stephen Field writing that “Corporations are persons within the meaning of the clauses in the Fourteenth Amendment to the Constitution concerning the deprivation of property, and concerning the equal protection of the laws.” This explicit holding cited Santa Clara County v. Southern Pacific Railroad (1886) as precedent, despite that case never actually ruling on corporate personhood. The underlying dispute involved a lawsuit over three hogs killed by the railroad—a trivial case that produced a profound constitutional holding. The Court’s willingness to decide major constitutional questions in minor property disputes reflects the era’s systematic expansion of corporate rights through incremental judicial decisions. By declaring corporate personhood “settled” just three years after the Santa Clara headnote and one year after Pembina’s explicit holding, the Court rapidly transformed a controversial legal theory into constitutional bedrock. This decision completed the trilogy of cases (Santa Clara 1886, Pembina 1888, Minneapolis Railway 1889) that established corporations as constitutional “persons” entitled to Fourteenth Amendment protections—protections originally designed to secure citizenship rights for formerly enslaved people. The doctrine would later enable Citizens United v. FEC (2010) and unlimited corporate political spending as “free speech.”