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Southern Pacific was hardly the only corporation to invoke the Bill of Rights in the name of deregulation, Bakan points out; although the law had been added to protect the rights of African Americans after the Civil War, only 19 individuals invoked it for protection between 1890 and 1910. Businesses, on the other hand, claimed 14th Amendment protection 288 times during that period. A 1976 Supreme Court case, Buckley v. Valeo, explicitly ruled that political donations were free speech and constitutionally protected.