Roscoe Conkling, a skillful lawyer and former powerful politicians who had served as a member of the United States Congressional Joint Committee on Reconstruction, which had drafted the Fourteenth Amendment, was the lawyer who argued an important case known as San Mateo County v. Southern Pacific Railroad before the Supreme Court in 1882. In this case, the issue was whether corporations are “persons” within the meaning of the Equal Protection Clause of the Fourteenth Amendment. Conkling argued that corporations were included in the meaning of the term person and thus entitled to such rights. He told the Court that he, as a member of the Committee that drafted this amendment to the Constitutional, knew that this is what the Committee had intended. Legal historians in the 20th Century examined the history of the drafting of the Fourteenth Amendment and found that Conkling had fabricated the notion that the Committee had intended the term “person” of the Fourteenth Amendment to encompass corporations. This San Mateo case was settled by the parties without the Supreme Court issuing an opinion however the Court's misunderstanding of the intention of the Amendment's drafters that had been created by Conkling’s likely deliberate deception was never corrected at the time. A second fraud occurred a few years later in the case of Santa Clara v. Southern Pacific Railroad, which left a written legacy of corporate rights under the Fourteenth Amendment. J. C. Bancroft Davis, an attorney and the Reporter of Decisions of the Supreme Court of the United States, drafted the “syllabus” (summary) of Supreme Court decisions and the “headnotes” that summarized key points of law held by the Court. These were published before each case as part of the official court publication communicating the law of the land as held by the Supreme Court. A headnote that Davis as court reporter published immediately preceding the court opinion in Santa Clara case stated: Davis added before the opinion of the Court: In fact, the Supreme Court decided the case on narrower grounds and had specifically avoided this Constitutional issue. The Supreme Court holding Supreme Court Justice Stephen Field seized on this deceptive and incorrect published summary by the court reporter Davis in Santa Clara v. Southern Pacific Railroad and cited that case as precedent in the 1889 case Minneapolis & St. Louis Railway Company v. Beckwith in support of the proposition that corporations are entitled to equal