In 1886, the U. S. Supreme Court ruled on Santa Clara County v.
Southern Pacific Railroad Company, a dispute regarding county property taxes levied on railway lines. The case itself centered on specific tax assessment procedures under California state law, but its historical legacy stems from an unlikely place: the court reporter's headnote. Before Chief Justice Morrison Waite delivered the official opinion, court reporter J.
C. Bancroft Davis included a brief summary stating that the Court did not wish to hear argument on whether the Fourteenth Amendment's Equal Protection Clause applied to corporations, as all justices were allegedly of the opinion that it did. Remarkably, the actual written opinion of the Court never addressed the constitutional question of whether corporations are legal persons under the Fourteenth Amendment, deciding the case purely on statutory state tax grounds.
Nevertheless, subsequent Supreme Court justices cited Davis's headnote as binding precedent, permanently altering American corporate law through a clerk's unofficial clerical summary.