A Corporation May Be An Individual But What About Tony The Tiger?
The California legislature was so upset by the Supreme Court's decision in Citizens United v. Federal Election Commission, 558 U.S. 310 (2010) that it passed a resolution memorializing its disagreement and asseverating that "Corporations are not people but, instead, are entities created by the laws of states and nations". AJR No. 22. Nonetheless, the legislature has previously concluded that while corporations may not be people, they can be "persons" or even "individuals". See, e.g., Cal. Corp. Code § 18 ("Person" includes a corporation as well as a natural person.") and § 27002(a) ("individual" includes every natural person, domestic or foreign private corporation . . . .").
Where does this leave animals? Do persons and individuals include tigers? According to the Animal Legal Defense Fund, a Tiger is an individual for purposes of the Freedom of Information Act which provides for expedited processing of records if “failure to obtain [the] requested records on an expedited basis . . . could reasonably be expected to pose an imminent threat to the life or physical safety of an individual[.]” 5 U.S.C. § 552(a)(6)(E)(v)(I). The Ninth Circuit Court of Appeals disagreed, holding "Where, as here, 'individual' is used as a noun with no corresponding group or category, its plain meaning is 'human being.'" Animal Legal Defense Fund v. Dept. of Agriculture, Case No. No. 18-16327 (Aug. 12, 2019).