Paul v. Virginia

E21372

Paul v. Virginia is an 1869 U.S. Supreme Court decision that held corporations are not “citizens” under the Constitution’s Privileges and Immunities Clause, allowing states to regulate foreign insurance companies.


Statements (43)

Predicate Object
instanceOf Privileges and Immunities Clause case
U.S. constitutional law case
United States Supreme Court case
affectedArea interstate insurance business
state police power over business regulation
areaOfLaw constitutional law
corporate law
insurance regulation
branchOfGovernment judicial branch of the United States government
citation 75 U.S. (8 Wall.) 168
constitutionalProvisionInterpreted Article IV, Section 2 of the United States Constitution
surface form: Article IV, Section 2, Privileges and Immunities Clause

Commerce Clause
surface form: Commerce Clause of the U.S. Constitution
country United States of America
surface form: United States
court Supreme Court of the United States
decisionDate 1869-03-01
decisionType reported decision
defendant Virginia
surface form: Commonwealth of Virginia
fullCaseName Paul v. Virginia self-link
holding A corporation is not a citizen within the meaning of the Privileges and Immunities Clause of Article IV of the U.S. Constitution.
Issuing an insurance policy is not commerce within the meaning of the Commerce Clause.
States may regulate and impose conditions on foreign insurance companies doing business within their borders.
jurisdiction United States of America
surface form: United States
languageOfProceeding English
laterLimitedBy United States v. South-Eastern Underwriters Association
legalDoctrine corporations are not citizens for Article IV Privileges and Immunities purposes
legalIssue Privileges and Immunities Clause
surface form: Privileges and Immunities Clause of Article IV

state regulation of foreign corporations
status of corporations as citizens
pageInUnitedStatesReports 168
party Virginia
surface form: Commonwealth of Virginia

Samuel B. Paul
plaintiff Samuel B. Paul
precedentFor limitation of corporate access to Privileges and Immunities Clause
state power to regulate foreign corporations
reporter United States Reports
result judgment for Virginia
shortDescription U.S. Supreme Court case holding that corporations are not citizens under the Privileges and Immunities Clause and upholding state regulation of foreign insurance companies.
stateInvolved Virginia
subjectMatter corporate citizenship for constitutional purposes
licensing of out-of-state insurance companies
timePeriod 19th century
volumeInUnitedStatesReports 75
yearDecided 1869

Referenced by (2)

Full triples — surface form annotated when it differs from this entity's canonical label.

Paul v. Virginia fullCaseName Paul v. Virginia self-link
Privileges and Immunities Clause keyCase Paul v. Virginia