Charlotte, Columbia and Augusta Railroad v. Gibbes: Corporate Personhood Reaffirmed

The Supreme Court again explicitly affirmed corporate personhood, holding that “It is again decided that private corporations are persons within the meaning of [the Fourteenth] Amendment.” The case involved South Carolina’s requirement that railroads pay the salaries and expenses of the state railroad commission, which Charlotte, Columbia and Augusta Railroad challenged as violating due process and equal protection. While the Court upheld the state’s authority to impose this burden on corporations benefiting from state-granted privileges, it simultaneously reinforced the doctrine that corporations possess Fourteenth Amendment rights. This decision represented continued judicial consolidation of corporate personhood as established precedent, citing the progression from Santa Clara (1886) through Pembina (1888) and Minneapolis Railway (1889). The Court’s reasoning that corporations could be both regulated AND entitled to constitutional protections created a framework that would eventually favor corporate rights over public regulation. Six years after the Santa Clara headnote, corporate personhood had transformed from a court reporter’s notation into repeatedly affirmed Supreme Court doctrine, systematically expanding constitutional protections intended for freed slaves to shield corporate power from democratic accountability.