No person shall be held to answer for a capital, or otherwise infamous crime, unless on a presentment or indictment of a Grand Jury, except in cases arising in the land or naval forces, or in the Militia, when in actual service in time of War or public danger; nor shall any person be subject for the same offence to be twice put in jeopardy of life or limb; nor shall be compelled in any criminal case to be a witness against himself, nor be deprived of life, liberty, or property, without due process of law; nor shall private property be taken for public use, without just compensation.
The Due Process Clause provides that no states shall deprive any
life, liberty or property without due process of law. A historical controversy has been waged concerning whether the framers of the Fourteenth Amendment intended the word
person to mean only natural persons, or whether the word was substituted for the word
citizen with a view to protecting corporations from oppressive state legislation.1 As early as the 1877 Granger Cases2 the Supreme Court upheld various regulatory state laws without raising any question as to whether a corporation could advance due process claims. Further, there is no doubt that a corporation may not be deprived of its property without due process of law.3 Although various decisions have held that the
liberty guaranteed by the Fourteenth Amendment is the liberty of natural,4 not artificial, persons,5 nevertheless, in 1936, a newspaper corporation successfully objected that a state law deprived it of liberty of the press.6