Editing Equal Protection Clause (section)

===The Supreme Court holding===
Supreme Court Justice Stephen Field seized on this deceptive and incorrect published summary by the court reporter Davis in ''Santa Clara v. Southern Pacific Railroad'' and cited that case as precedent in the 1889 case ''Minneapolis & St. Louis Railway Company v. Beckwith'' in support of the proposition that corporations are entitled to equal protection of the law within the meaning of the Equal Protection Clause of the Fourteenth Amendment. Writing the opinion for the Court in ''Minneapolis & St. Louis Railway Company v. Beckwith'', Justice Field reasoned that a corporation is an association of its human shareholders and thus has rights under the Fourteenth Amendment just as the members of the association.<ref>Adam Winkler, "We the Corporations, How American Businesses Won Their Corporate Rights" (New York: Liveright Publishing Corporation, 2018) pp. 154-156. Justice Field was a friend of railroad magnate [[Leland Stanford]], owner of [[Southern Pacific Railroad]], the corporation that had filed these lawsuits, and, as a Supreme Court justice and federal appellate judge for years, had a pro-corporationist agenda. (Adam Winkler, "We the Corporations, How American Businesses Won Their Corporate Rights" (New York: Liveright Publishing Corporation, 2018) pp. 140-143.) Justice Field must have known that in the ''Santa Clara'' case the Supreme Court explicitly declined to address the Constitutional issue because, in a companion case to ''Santa Clara'', Justice Field had urged the Court to address precisely this issue by endorsing such corporate rights on Fourteenth Amendment grounds, and he harshly criticized his fellow justices for failing to do so. (Adam Winkler, "We the Corporations, How American Businesses Won Their Corporate Rights" (New York: Liveright Publishing Corporation, 2018) pp. 156-157)</ref>

In this Supreme Court case ''Minneapolis & St. Louis Railway Company v. Beckwith'', Justice Field, writing for the Court, thus took this point as established Constitutional law. In the decades that followed, the Supreme Court often continued to cite and to rely on ''Santa Clara v. Southern Pacific Railroad'' as established precedent that the Fourteenth Amendment guaranteed equal protection of the law and due process rights for corporations, even though in the Santa Clara case the Supreme Court held or stated no such thing.<ref>Adam Winkler, "We the Corporations, How American Businesses Won Their Corporate Rights" (New York: Liveright Publishing Corporation, 2018) pp. 156-157</ref> In the late 19th and early 20th centuries, the clause was used to strike down numerous statutes applying to corporations. Since the [[New Deal]], however, such invalidations have been rare.<ref>See {{cite journal |last=Currie |first=David P. |year=1987 |title=The Constitution in the Supreme Court: The New Deal, 1931–1940 |journal=University of Chicago Law Review |volume=54 |pages=504–555 |doi=10.2307/1599798 |issue=2 |jstor=1599798|url=https://chicagounbound.uchicago.edu/journal_articles/3828 |type=Submitted manuscript |url-access=subscription }}</ref>