A court reporter's unofficial summary quietly grants corporations the same constitutional protections as individual citizens

The U.S. Supreme Court decided Santa Clara County v. Southern Pacific Railroad Company, a tax dispute over California railroad property assessments. Before oral argument, Chief Justice Morrison Waite announced that the Court considered corporations to be persons protected by the Fourteenth Amendment Equal Protection Clause. Court reporter J.C. Bancroft Davis embedded this pre-argument remark into the official headnote, which later courts cited as binding precedent even though it did not appear in the formal opinion.