Gale Encyclopedia Of American Law 3Rd Edition Volume 8 P51 pptx

SANCTION To assent, concur, confirm, approve, or ratify. The part of a law that is designed to secure enforcement by imposing a penalty for violation of the law or offering a reward for its observance. A punitive act taken by one nation against another nation that has violated a treaty or INTERNATIONAL LAW. Sanction is a broad term with different meanings in different contexts. It can be used to describe tacit or explicit approval. Used in this sense, the term usually is used in assigning liability to a party who was not actively involved in wrongdoing but who did nothing to prevent it. For example, if the upper-level managers of a business knew that their employees were using unfair employment practices and did nothing to stop them, it may be said that the managers sanctioned the unfair practices. The term sanction also can describe dis- agreement and condemnation. In CRIMINAL LAW, a sanction is the punishment for a criminal offense. The criminal sanction for a criminal DEFENDANT varies according to the crime and includes such me asures as death, INCARCERATION, PROBATION, COMMUNITY SERVICE, and monetary fines. In CIVIL LAW, a sanction is that part of a law that assigns a penalty for violation of the law’s provisions. The most common civil sanction is a monetary fine, but other types of sanctions exist. Depending on the case, a sanction may be the suspension or revocation of a business, professional, or hobby license, or a court order commanding a person to do or refrain from doing something. A sanction may even be tailored to the case at hand. For instance, under Rule 37 of the Federal Rules of CIVIL PROCEDURE, if a party refuses to obey a discovery order, or an order to relinquish requested evidence, the court may order that the evidence sought be automatically construed in favor of the request- ing party, refuse to allow the disobedient party to make claims or defenses related to the evidence, stay or postpone the case until the discovery order is obeyed, dismiss the action or render judgment for the requesting party, declare the disobedient party in CONTEMPT of court, or make any other order that is just under the circumstances. In civil LITIGATION, sanctions are slightly different from remedies. A remedy is the relief accorded to a victorious litigant. The remedy may be money damages, an order that forbids or commands the opposing party or parties to do or refrain from doing a certain act or acts, or some other result favorable to the victorious litigant. Remedies are not always intended to punish a person, while sanctions are always punitive. Nevertheless, remedies and sanctions are similar in that they refer to a loss that a civil litigant must bear if she is found liable for a civil wrong. In some cases a party may have to remedy another party’s loss as well as suffer criminal and civil sanctions, all for the same act. For example, if an attorney is professionally negli- gent in his handling of a client’s case and steals funds from the client’s trust account, the attorney may face a MALPRACTICE civil suit from the aggrieved client in which the client asks for money as a remedy for the malpractice. The attorney also may suffer sanctions from the professional conduct committee of the state bar association and criminal sanctions from a prosecution for the theft. The contempt-of-court offense provides a flexible form of sanction. Contempt-of-court sanctions may be either civil or criminal. The court may order a party to pay a fine or suffer some setback in the case (civil contempt), or it may order that the party be placed in jail (criminal contempt). The basic difference between the two is that criminal contempt is an act of disrespect toward the court, whereas civil contempt acts tend to be less offensive transgressions, such as the unintentional failure to comply with discovery orders or to perform other acts ordered by the court. Most courts possess inherent authority to sanction attorneys or parties for misconduct that occurs during a legal proceeding. However, judges must be careful to issue sanctions in an impartial ma nner. Attorneys and parties w ho face judicial sanctions can ask the judge to RECUSE himself or herself from the matter if they believe the judge is incapable of making a fair determination. A denial of a motio n to recuse is appealable, and APPELLATE courts will closely scrutinize the circumstances of the denial. For example, the Arkansas SUPREME COURT ruled that a trial court judge should have recused himself before issuing sanctions against an attorney because the trial judge had an obvious bias toward the atto rney. According to the state supreme court, the trial court judge repeatedly shut off the attorney when the attorney sought GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 488 SANCTION answers to his questions, telling the attorney, “I’m not up here to answer your questions.” The trial judge also told the attorney that “I can do anything I want to. I’m the judge.” Allen v. Rut ledge, 355 Ark. 392, 139 S.W.3d 491 (2003); One type of non-judicial form of sanction is an ADMINISTRATIVE AGENCY sanction against a corporation. Corporations must follow various rules passed by federal, state, and local admin- istrative agencies authorized by lawmaking bodies to regulate specific topics of government concern. If a business does not obey agency rules that apply to it, it may face sanctions levied by the administrative agency responsible for enforcing the rules. For example, federal and state environmental protection agencies are authorized by statute to levy fines against businesses that violate environmental laws and regulations. An international sanction is a special form of sanction taken by one country against another. International sanctions are measures that are designed to bring a delinquent or renegade state into compliance with expected rules of conduct. International sanctions may be either non-forceful or military. Military sanc- tions can range from cutting off access to limited strikes to full-scale war. Non-forcef ul international sanctions include diplomatic mea- sures, such as the withdrawal of an ambassador, the severing of diplomatic relations, or the filing of a protest with the UNITED NATIONS; financial sanctions such as denying aid or cutting off access to financial institutions; and economic sanctions such as partial or total trade embar- goes. The U.N. Security Council has the authority to impose econom ic and military sanctions on nations that pose a threat to peace. FURTHER READINGS “Limits of the Criminal Sanction.” 2002. New Jersey Law Journal (July 29). Pate, William H. 2002. “To Sanction or Not to Sanction: Why Arguing against the Court’s Precedent Is Not an Automatic Rule 11 Violation.” Campbell Law Review 25 (fall). v SANFORD, EDWARD TERRY An important influence on the develop ment of civil liberties, Edward Terry Sanford served on the U.S. Supreme Court from 1923 to 1930. Sanford was a native of Tennessee with a cosmopolitan education, and before serving on the Court, he had a PRIVATE LAW practice, served in the JUSTICE DEPARTMENT, and was a federal district judge in his home state for 14 years. While on the Court, Sanford’s views were largely moderate, and in his lifetime he was over- shadowed by his highly visible contemporaries. Nonetheless, Sanford’s opinions on civil liberties helped advance the guarantees of the BILL OF RIGHTS : in two major opinions delivered in the 1920s, he laid the groundwork for modern Supreme Court decisions that restrict the power of states to limit FIRST AMENDMENT rights to FREEDOM OF SPEECH. Sanford was born in Knoxville, Tennessee, on July 23, 1865, the son of a lumber and construction millionaire. He earned four degrees from the University of Tennessee and Harvard, and studied languages in France and Germany. At Harvard Law School, he distin- guished himself as the editor of the Harvard Law Review and graduated magna cum laude. He began practicing law in Tennessee in the 1890s. He then lectured in law at the University of Tennessee from 1898 to 1906 before moving to Washington, D.C., for his first federal job. ▼▼ ▼▼ Edward Terry Sanford 1865–1930 18501850 19001900 19251925 19501950 18751875 ❖ 1865 Born, Knoxville, Tenn. 1861–65 U.S. Civil War ◆ 1883 Earned B.A. from University of Tenn. ◆ 1889 Earned M.A. and LL.B. from Harvard University ◆◆ 1906 Appointed special assistant prosecutor to U.S. attorney general 1907 Appointed assistant U.S. attorney general 1914–18 World War I 1908–23 Served as associate justice of the U.S. District Court in Tenn. 1939–45 World War II 1930 Died, Washington, D.C. ◆ ❖ 1923–30 Served as associate justice of the U.S. Supreme Court 1925 Wrote majority opinion in Gitlow v. New York 1927 Wrote majority opinion in Fiske v. Kansas ◆ WE MAY AND DO ASSUME THAT THE FREEDOM OF SPEECH AND OF THE PRESS ARE AMONG THE FUNDAMENTAL PERSONAL RIGHTS AND LIBERTIES PROTECTED FROM IMPAIRMENT BY THE STATES. —EDWARD T. S ANFORD GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION SANFORD, EDWARD TERRY 489 Sanford’s federal law career began in prosecution and rapidly took him to the federal bench. He joined the Justice Department in 1906 as a special assistant prosecutor, and a year later he was made an assistant attorney general. By 1908, Sanford returned to Tennessee as a federal district judge, a positio n he held until 1923. His specialties were BANKRUPTCY and EQUITY cases. On the bench, he developed a reputation for open-mindedness, fairness, and leniency, at times reversing his own decisions. He was highly driven and nervously energetic, and would pace and chain-smoke in his chambers while considering his busy docket. In 1923 Sanford’snominationtotheSu- preme Court came at the behest of his friends, Chief Justice WILLIAM HOWARD TAFT and Attorney General HARRY M. DAUGHERTY.Thetwomen convinced President WARREN G. HARDING of Sanford’s breadth of education and varied experience, which included service on the LEAGUE OF NATIONS . The nomination succeeded easily in the Senate, and Sanford sat on the Court for seven years until his death in 1930. He wrote 130 opinions, many of them addressing issues related to government, business, and especially bankruptcy. Although neglected by history because of the accomplishments of his celebrated contemporar- ies, Sanford made a major contribution in the area of civil liberties. In particular, he helped develop the so-called incorporation doctrine— the Supreme Court’s view that the Bill of Rights applies not only to the federal government but also, in large part, to the states. During much of the nineteenth century, states conferred fewer rights upon their citizens than those extended by the federal Bill of Rights, even after RATIFICATION of the FOURTEENTH AMENDMENT.With the intervention of the Supreme Court, this began to change at the turn of the century. In the mid-1920s Sanford helped effect the change in two important cases concerning freedom of speech. The first case dealt with a state’s power to control the press. In GITLOW V. NEW YORK, 268 U.S. 652, 45 S. Ct. 625, 69 L. Ed. 1138 (1925), the Court considered New York’s conviction of a leftist auth or under the state’s ANARCHY law of 1902. The broader question for the Court was, Should the First Amendment be extended to the states? Sanford’s opinion upheld the convic tion because, in the Court’s view, states should be free to prosecute citizens who advocate violent overthrow of government. But on the broader question of the Bill of Rights, Sanford wrote in DICTA that the First Amendment applied to the states through the Fourteenth Amendment. Gitlow planted the seed for the incorporation of the First Amendment, and for subsequent cases in which the Court would strike down state laws that violated the First Amendment. In 1927 the Court upheld a defense based on the doctrine enunciated in Gitlow in Fiske v. Kansas, 274 U.S. 380, 47 S. Ct. 655, 71 L. Ed. 1108. In his opinion, Sanford underscored that states must guarantee First Amendment rights. Throughout his tenure on the Court, Sanford voted consistently with Chief Justice Taft. Sanford died at age 64 on March 8, 1930— the same day that Taft died. FURTHER READINGS Friedman, Leon, and Fred L. Israel, eds. 1995. The Justices of the United States Supreme Court, 1789–1969: Their Lives and Major Opinions. New York: Chelsea House. v SANGER, MARGARET HIGGINS A feminist and founder of the Planned Parent- hood FEDERATION of America, Margaret Higgins Sanger battled the government and the Roman Catholic Church to establish the legitimacy of BIRTH CONTROL. Edward T. Sanford. COLLECTION OF THE SUPREME COURT OF THE UNITED STATES GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 490 SANGER, MARGARET HIGGINS Sanger was born September 14, 1879, in Corning, New York, to Michael Higgins, an Irish stonecutter, and Annie Purcell Higgins, the daughter of an Irish day laborer. Sanger’s mother, who had five more children and suffered chronic tuberculosis, died at the age of 50 in 1899. Sanger blamed her mother’s death on the strain of bearing eleven children. Following her mother’s death, Sanger began nursing training at White Plains Hospital. She often accompanied doctors to patients’ home s to deliver babies, and she frequently had to deliver children herself. Many of the new mothers asked Sanger what they could do to prevent another pregnancy. She, in turn, asked the doctors, but they gave her no information and took little interest in the women’s dilemma. While completing her nursing training, Sanger met William Sanger, an architect, whom she married in 1902. He was a Ger man Jew and a socialist who was active in the radical causes of the day. By 1912 the Sangers and their three children had moved to Greenwich Village, where the couple became involved in politics and the arts and entertained some of the most radical intellectuals of the time. Sanger became deeply involved with the SOCIALIST PARTY. While recruiting for the organization, she visited many working-class families with six and seven children that were forced to make their home in two- and three-room tenements. She found that the women lived in dread of having more children and the resulting increas e in poverty, and she concluded that women needed the right to control their own bodies. She soon began speaking publicly on the problems of family life, connecting the size of the family with the economic problems of the working class. Her speeches became so popular that she was asked to turn them into a series of articles for the Call, a New York socialist newspaper. In her 12-week series, entitled “What Every Woman Should Know,” Sanger explained puber ty, the reproductive organs, and sexually transmitted diseases. After the paper printed an article about gonorrhea, the authori- ties threatened that if it published a planned article on syphilis, its mailing permit would be canceled under the Comstock Act of 1873, a ▼▼ ▼▼ Margaret Higgins Sanger 1879–1966 1875 1925 1950 1975 1900 ❖ 1879 Born, Corning, N.Y. 1914–18 World War I 1939–45 World War II ❖ ◆ 1914 First issue of Woman Rebel published; indicted under the Comstock Act for the mailing of obscene material ◆ 1916 Opened first U.S. birth control clinic; served 30 days in prison for distributing birth control information ◆ 1918 Crane decision allowed doctors to give out birth control information ◆ 1923 Opened the Birth Control Clinical Research Bureau ◆ 1921 Formed the American Birth Control League ◆ 1931 Testified before Congress concerning the Doctor's Bill ◆ ◆ ◆ 1952 Helped found the International Planned Parenthood Federation 1942 Birth Control Federation of America renamed Planned Parenthood Federation of America ◆ 1960 Birth control pills first marketed 1936 U.S. Court of Appeals ruled in United States v. One Package that the Comstock Act did not apply to physicians' packages 1950–53 Korean War 1961–73 Vietnam War 1966 Received the Presidential Medal of Valor; died, Tucson, Ariz. Margaret Sanger. AP IMAGES GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION SANGER, MARGARET HIGGINS 491 strict CENSORSHIP law that barred the mailing of “obscene” material. The law was named for Anthony Comstock, a special agent of the post office with authority to open the mail and determine whether materials were obscene. Along with her speaking and writing, Sanger returned to nursing in New York and spent much of her time assisting with home births and living with the families for several weeks afterward. She observed that the women had repeated pregnan- cies and were obsessed with methods of prevent- ing conception. They sought illegal and cheap ABORTIONS, which often caused injury or death, and tried dangerous cures of their own, such as drinking turpentine and inserting instruments into the uterus. After one woman died following her second self-induced ABORTION,Sangerwas distraught and walked the streets for hours before returning home. That night, Sanger decided to devote her life to educating women about their bodies and methods of contraception. Sanger began her work by scouring libraries for information on preventing conception. After months of reading and r esearch, she was convinced that no practical information existed in the United States, and she traveled to France with her family. In Paris Sanger found that French women were well versed in contraceptive meth- ods. She talked to druggists, midwives, doctors, and w orking women, and noted formulas for suppositories and douches, which she planned to write up as a pamphlet for U.S. women. Returning home to New York, she began publishing a monthly magazine called the Woman Rebel. She deliberately decided to use the publication to engage in a frank discussion of women’s liberation from the fear and reality of unplanned pregnancies, knowing that she would soon run afoul of Anthony Comstock. Sanger realized that the new movement needed a name, and after much discussion, she and a group of supporters agreed to call it birth control. In April 1914, four weeks after the first issue of the Woman Rebel was p ublis hed, t he po st office notified Sanger that the magazine was unmailable under the Comstock Act. While she skirmished with Comstock over her maga- zine, Sanger worked on her pamphlet on contraceptive techni ques, c alled Family Li mita - tion, in which she described the practical knowledge she had gathered in Europe. Sanger visited 22 printers in one week, trying to find someone who would produce the pamphlet. Finally, 100,000 copies were printed, addressed, and stored in S an Fr ancisco, Chicago, and Pittsburgh, to be mailed on her prearranged signal, when she thought she would be safe from Comstock’s interference. In August 1914, Sanger was indicted on charges of violating the Comstock Act. When it became clear that the judge hearing her case was biased against her, she fled to Europe to gain time to prepare her case properly. She sailed from Canada under a false name and without a passport. From the ship, where she was safely outside U.S. legal jurisdiction, Sanger sent telegrams containing the prearranged code word that indicated it was time to send out her pamphlet on contraception. After landing in Liverpool, she traveled on to London, where news of the Woman Rebel had made her a celebrity in radical circles. She later moved to Holland, which had the lowest infant death rate in the world and where all mothers were taught about contracep- tion. There, Sanger learned how to examine women and advise them on which of the 15 available birth control devices were appropriate. As a result of her experience in Europe, she learned the necessity of the medical community’s involvement in the birth control movement and the importance of keeping thorough records and conducting follow-up studies. In October 1915 Sanger sailed home. She contacted the district attorney about her case, and a hearing was scheduled for the following January. But in November 1915, the Sangers’ daughter, Peggy, died of pneumonia, and Sanger sank into a severe depression. She insisted on going ahead with her trial, however, and received an outp ouring of support from people across the country who had heard of her loss. Eventually the charges were dismissed on the grounds that they were two years old and that Sanger had not made a practice of publishing obscene articles. Although this dismissal prevented the Comstock Act from being challenged in the courts, the publicity surrounding Sanger’s case made the entire country aware of the birth control movement. Sanger next notified her supporters of her intent to establish free clinics throughout the country, at which women could receive instruc- tion in birth control. Sanger rented a storefront tenement in the Brownsville section of Brook- lyn, where many newly arrived immigrants lived. The three women printed 5,000 circulars A FREE RACE CANNOT BE BORN OF SLAVE MOTHERS . —MARGARET SANGER GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 492 SANGER, MARGARET HIGGINS in English, Yiddish, and Italian, advertising the clinic and offering contraceptive information for ten cents, and posted them around the neighborhood. The posters read, “Mothers! Can you afford to have a large family? Do you want any more children? If not, why do you have them?” In October 1916 Sanger, along with her sister Ethel Byrne, who was a nurse, and Fania Mindell, another supporter, opened the first birth control clinic in the United States. After only nine days, more than 400 women had come to the clinic for assistance. Among them was an undercover policewoman, who arrested Sanger, Byrne, and Mindell and confiscated all the patient records, pamphlets, and contra- ceptives. The women were charged with dis- seminating birth control information and maintaining a public NUISANCE.Byrnewasfound guilty and sentenced to 30 days in jail, where she nearly died from a hunger strike before the governor pardoned her. Mindell was found guilty of selling copies of “What Every Woman Should Know” and fined 50 dollars. Sanger was convicted and sentenced to thirty days in the workhouse, where she gave lectures on birth control to the other inmates and taught them to read and write. After her release, Sanger decided to focus on changing the laws on contraception and edu- cating women about birth control techniques. Her conviction for running the birth control clinic had been upheld by the New York Supreme Court in People v. Sanger, 179 App. Div. 939, 166 N.Y.S. 1107 (1917), and she appealed to the state’s high court, the New York Court of Appeals. In January 1918, in an opinion that became known as the Crane decision after the authoring judge, Frederick Crane, the appellate court upheld the lower court (Sanger, 222 N.Y. 192, 118 N.E. 637). But the court interpreted the criminal laws broadly, holding that doctors could give out birth control information to any married person to protect his or her health. This meant that clinics could operate freely and that they would be under the supervision of medical personnel, where Sanger thought they belonged. By 1920 more than 25 birth control leagues were operating, and Mindell’sconvic- tion for distributing literature about contra- ception was reversed, which meant that pamphlets and books could more easily be distributed. In 1921 Sanger formed the Ameri- can Birth Control League. The Catholic Ch urch came to lead the opposition to Sanger’s efforts, and she continued to battle the church throughout her life. Sanger attacked the Comstock law, estab- lishing the National Committee for Federal Legislation for Birth Control, headquartered in Washington, D.C., to gather support for federal legislation dubbed the Doctor’s Bill. By 1931 hundreds of medical, political, religious, and labor organizations supported the bill. When Sanger appeared before a subcommittee of the Senate Judicial Committee in February 1931, she testified that based on statistics for the period since the Comstock Act took effect in 1873, one-and-a-half million women had died during pregnancy and childbirth; 700,000 illegal abortions had been performed each year; and fifteen million children had died during their first year because of poverty or their mothe r’s poor health. But the proposed legislation was vehemently oppos ed by the Catholic Church, the Patriotic Society, the Purity League, and other groups, and was defeated. After further attempts to pass the legislation were unsuccessful, Sanger decided to turn to the courts. In 1933, she had a new type of pessary (vaginal suppository) sent to Dr. Hannah Stone, in New York, but the package was seized under the Comstock Act. Stone filed charges. After a trial, the court ruled that the doctor was entitled to the package (United States v. One Package, 13 F. Supp. 334 [S.D.N.Y. 1936]). The government appealed to the U.S. Court of Appeals for the Second Circu it, which upheld the lower court, ruling that the aim of the Comstock law was not to “prevent the importation, sale, or carriage by mail of things which might intelligently be employed by conscientious and competent physicians for the purpose of saving life or promoting the well being of their patients” (One Package, 86 F.2d 737 [2d Cir. 1936]). In 1937 the AMERICAN MEDICAL ASSOCIATION adopted the position that all doctors should receive infor- mation about the legal dispensation of contra- ceptives and that new contraceptive techniques should be studied. In 1939 the Birth Control Clinical Research Bureau and the Birth Control League merged into the Birth Control Federation of Ame rica, which was renamed the Planned Parenthood Federation of America in 1942. Sanger GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION SANGER, MARGARET HIGGINS 493 continued her work, initiating birth control programs in rural clinics. Here, she decided that the relatively expensive and difficult-to-use diaphragm was impractical and that women needed a birth control pill or injection. In the 1950s she supported the work of Dr. Gregory Pincus, whose research eventually produced the birth control pill. In 1966, at the age of 82, Sanger received the Presidential Medal of Valor from LYNDON B. JOHNSON. Later that year, on Septemb er 6, 1966, she died in Tucson, Arizona. FURTHER READINGS Chesler, Ellen. 1992. Women of Valor: Margaret Sanger and the Birth Control Movement in America. New York: Simon & Schuster. Coigney, Virginia. 1969. Margaret Sanger: Rebel with a Cause. New York: Doubleday. Reed, Miriam. 2003. Margaret Sanger: Her Life in Her Words. Fort Lee, N.J.: Barricade Books. Sanger, Margaret. 2004. The Autobiography of Margaret Sanger. Mineola, N.Y.: Dover. Topalian, Elyse. 1984. Margaret Sanger. New York: Watts. CROSS REFERENCES Griswold v. Connecticut; Women’s Rights. SANITY Reasonable understanding; sound mind; posses- sing mental faculties that are capable of distin- guishing right from wrong so as to bear legal responsibility for one’s actions. SANTA CLARA COUNTY V. SOUTHERN PACIFIC RAILROAD COMPANY An 1886 U.S. Supreme Court decision, Santa Clara County v. Southern Pacific Railroad Company, 118 U.S. 394, 6 S. Ct. 1132, 30 L. Ed. 118, has been interpreted that the term person as used in the EQUAL PROTECTION CLAUSE of the FOURTEENTH AMENDMENT applies to corpora- tions as well as to natural persons. The Southern Pacific Railroad Company refused to pay a tax assessed by the California Board of Equalization upon its franchise, road- ways, roadbeds, fences, and rolling stock. The county brought an action in state court against the railroad to recover the delinquent taxes. The railroad had the action removed to the federal district court. The court agreed with the defendant that the assessment of the tax was void because the board had no jurisdiction to act. It also ruled that the defendant had been denied equal protection of the law because the assessment of the property was made at full monetary value without the discount that was given to individual property owners for out- standing mortgages on their property. The county filed a writ of error to the federal court, and the U.S. Supreme Court heard the case. The Court agreed with the railroad that the state board had no jurisdiction to assess the tax. The assessment of taxes by the board on fences belonging to the railroad was deemed void because the board was authorized by the state constitution to assess only “the franchise, road- way roadbed, rails, and rolling stock.” The Court rejected the argument that the fences constituted part of the roadway for purposes of taxation. The constitution required a separate assessment for “land, and improvements thereon” and a state statute expressly included the term fence within the categories of improvements. The state board acting through the county sought to have the plaintiff liable for a single sum, incorporating taxes assessed upon various types of property, including property that the board had no power to assess. The Court declared that since part of the assessment was illegal, it could not support an action for the county to recover the entire tax; therefore, it affirmed the judgment for the defendants. The Court did not explicitly discuss the Fourteenth Amendment in its opinion, basing its decision on the invalidity of the assessment. In its statement of the facts of the case, it did, however, set out the Fourteenth Amendment claims of the railroad. The California constitu- tion denied “railroads and other quasi public corporations” equal protection of laws as guaranteed by the Fourteenth Amendment to the Constitution because the board did not reduce the value of property for assessment purposes by the amount of any outstanding mortgage debts on it, as it did for property owned by natural persons or other corpora- tions. Although the Supreme Court did not specifically rule on the constitutionality of the treatment of the railroad by the state, the case of County of Santa Clara v. Southern Pacific Railroad Company is interpreted to support the principle that both corporations and natural persons are entitled to equal protection of laws pursuant to the Fourteenth Amendment to the Constitution. GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 494 SANITY . state supreme court, the trial court judge repeatedly shut off the attorney when the attorney sought GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 488 SANCTION answers to his questions, telling the attorney, “I’m. University of Tennessee from 189 8 to 1906 before moving to Washington, D.C., for his first federal job. ▼▼ ▼▼ Edward Terry Sanford 186 5–1930 185 0 185 0 19001900 19251925 19501950 187 5 187 5 ❖ 186 5 Born, Knoxville, Tenn. 186 1–65 U.S Sanford. COLLECTION OF THE SUPREME COURT OF THE UNITED STATES GALE ENCYCLOPEDIA OF AMERICAN LAW, 3RD E DITION 490 SANGER, MARGARET HIGGINS Sanger was born September 14, 187 9, in Corning, New