Cite as: 538 U. S. 119 (2003)
Opinion of the Court
persons may"); see also 1 J. Dillon, The Law of Municipal Corporations 92 (rev. 2d ed. 1873). Indeed, "[t]he archetypal American corporation of the eighteenth century [was] the municipality"; only in the early 19th century did private corporations become widespread. M. Horwitz, The Transformation of American Law, 1780-1860, p. 112 (1977). This history explains how the Court in Cowles could conclude "automatically and without discussion" that municipal corporations, like private ones, "should be treated as natural persons for virtually all purposes of constitutional and statutory analysis." Monell v. New York City Dept. of Social Servs., 436 U. S. 658, 687-688 (1978); see Cowles, supra, at 121 (describing the question as one that "presents but little difficulty").7
Of course, the meaning of "person" recognized in Cowles is the usual one, but not immutable, see Monell, supra, at 688, and the County asks us to take a cue from the qualification included in the later definition in the Dictionary Act, Act of Feb. 25, 1871, § 2, 16 Stat. 431, that "the word 'person' may extend and be applied to bodies politic and corporate . . . unless the context shows that [it was] intended to be used in a more limited sense." Cf. J. Angell & S. Ames, A Treatise on the Law of Private Corporations Aggregate 4 (rev. 3d ed. 1846) ("The construction is, that when 'persons' are mentioned in a statute, corporations are included if they fall within the general reason and design of the statute"). The County invokes two points of context that it takes as
7 The County and some of its supporting amici urge a further distinction between full-fledged municipal corporations such as towns and cities, which were incorporated at the request of their inhabitants, and "quasi corporations" such as counties, which were unilateral creations of the State. See Barnes v. District of Columbia, 91 U. S. 540, 552 (1876). While the liability of quasi corporations at common law may have differed from that of municipal corporations, see ibid., both were treated equally as legal "persons." Indeed, Cowles itself applied to an Illinois county like Cook County.
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