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. 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. 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. Between Plessy and Brown In Missouri ex rel. Gaines v. Canada (1938), Lloyd Gaines was a black student at Lincoln University of Missouri, one of the historically black colleges in Missouri. He applied for admission to the law school at the all-white University of Missouri, since Lincoln did not have a law school, but was denied admission due solely to his race. The Supreme Court, applying the separate-but-equal principle of Plessy, held that a State offering a legal education to whites but not to blacks violated the Equal Protection Clause. In Shelley v. Kraemer (1948), the Court showed increased willingness to find racial discrimination illegal. The Shelley case concerned a privately made contract that prohibited "people of the Negro or Mongolian race" from living on a particular piece of land. Seeming to go against the spirit, if not the exact letter, of The Civil Rights Cases, the Court found that, although a discriminatory private contract could not violate the Equal Protection Clause, the courts' enforcement of such a contract could; after all, the Supreme Court reasoned, courts were part of the state. The companion cases Sweatt v. Painter and McLaurin v. Oklahoma State Regents, both decided in 1950, paved the way for a series of school integration cases. In McLaurin, the University of Oklahoma had admitted McLaurin, an African-American, but had restricted his activities there: he had