Footnote of the Day: Citizens United and "the Bellotti footnote" Part II

In First National Bank of Boston v. Bellotti, 435 U. S. 765 (1978),  relied upon by the Court in Citizen’s United v. Federal Election Comm’n, __ US __, 130 S.Ct. 876 (2010), the Court considered a Massachusetts statute that prohibited banks and other businesses from making contributions or expenditures to influence the outcome of a vote on any question submitted to voters other than questions materially affecting the property, business or assets of the corporation.

We’ve previously discussed footnote 26 of Bellotti.  

But perhaps footnote 15 is even more trenchant:

It has been settled for almost a century that corporations are persons within the meaning of the Fourteenth Amendment. Santa Clara County v. Southern Pacific R. Co., 118 U.S. 394(1886); see Covington & Lexington Turnpike R. Co. v. Sanford, 164 U.S. 578 (1896).

 435 U.S. at 780 n.15. 

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