 Taylor v. Beckham established as a judicial principle that public offices are mere agencies or trusts , and not property protected by the Fourteenth Amendment . The U.S. Court of Appeals for the Second Circuit in 2005 stated that the Supreme Court subsequently had adopted a more expansive approach to identifying " property " within the meaning of the Fourteenth Amendment , but that it is the Supreme Court 's prerogative alone to overrule one of its precedents . 
