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MISSOURI PACIFIC RAILROAD v. HUMES 115 U.S. 512 (1885)

A CORPORATION, invoking the FOURTEENTH AMENDMENT, employed SUBSTANTIVE DUE PROCESS against a state statute, but the Supreme Court, led by Justice STEPHEN J. FIELD, unanimously construed due process in an exclusively procedural sense. A statute might seriously depreciate the value of property, Field declared, but "if no rule of justice is violated in the provisions for the enforcement of such a statute," it could not be said to deprive a person of property without due process. The case was a replay of Davidson v. New Orleans (1878), which Field quoted. In 1886, the Court began to abandon the Davidson-Humes view of due process.