Chicago Life Ins. Co. v. Needles, 113 U.S. 574 (1885)
U.S. Supreme CourtChicago Life Ins. Co. v. Needles, 113 U.S. 574 (1885)
Chicago Life Insurance Company v. Needles
Argued January 29, 1885
Decided March 2, 1885
113 U.S. 574
When the final judgment of a state court necessarily involves an adjudication of a claim made therein that a statute of the state is in derogation of rights secured to a party by the Constitution, this Court has jurisdiction of the cause in error, although the state court did not in terms pass upon the point.
A grant of corporate franchises is necessarily subject to the condition that the privileges and franchises conferred shall not be abused or employed to defeat the ends for which they were conferred, and that when abused or misemploped, they may be withdrawn by proceedings consistent with law.
A corporation is subject to such reasonable regulations, as the legislature may from time to time prescribe, as to the general conduct of its affairs, serving only to secure the ends for which it was created and not materially interfering with the privileges granted to it.
The establishment against a corporation, before a judicial tribunal in which opportunity for defense is afforded, that it is insolvent or that its condition is such as to render its continuance in business hazardous to the public or to those who do business with it, or that it has exceeded its corporate powers, or that it has violated the rules, restrictions, or conditions prescribed by law constitute sufficient reason for the state which created it to reclaim the franchises and privileges granted to it.
An adjudication by a competent tribunal, after full opportunity for defense, that a corporation against which the foregoing grounds have been established shall no longer enjoy its corporate franchises and privileges does not deprive it of its property without due process of law or deny to it equal protection of the law.
The facts are stated in the opinion of the court.