The U.S. Supreme Court case California v. Southern Pacific Company in 1894 revolved around a dispute over taxation of railroad property by the state of California. The Southern Pacific Railroad argued that it was being unfairly taxed, as its properties were assessed at higher rates than other properties within the state, violating the Equal Protection Clause of the Fourteenth Amendment to the Constitution which guarantees equal protection under law for all citizens and corporations alike. The court ruled in favor of Southern Pacific Company, stating that there had been an unfair application of tax laws against them compared to other businesses and individuals within California's jurisdiction. This decision reinforced corporate personhood rights under American constitutional law.

In the dissenting opinion for California v. Southern Pacific Company, Justice Field argued that corporations should not be granted the same rights as individuals under the Fourteenth Amendment. He contended that a corporation is an artificial entity created by state law and thus cannot enjoy or exercise privileges and immunities inherent in citizenship of a natural person. The justice also expressed concern about potential abuse of these rights by corporations to evade taxes or other obligations to society, which he believed could undermine public welfare and good governance. Furthermore, he disagreed with the majority's interpretation of "person" in the Equal Protection Clause to include corporations, asserting it was intended only for individual citizens who were previously enslaved. Overall, his dissent emphasized preserving constitutional protections specifically for human beings rather than extending them broadly to corporate entities.