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48) These public purposes, whether achieved in some way by private corporations, government corporations, or eleemosynary corporations, are the ultimate reasons why the government ought to protect their rights once created, including granting corporations standing in court.
For Marshall, chartered corporations included not only private commercial corporations and eleemosynary corporations, but also cities and the United States government itself.
Angell and Ames focused their attention on topics critical to religious and eleemosynary corporations such as means of creation -- prescription, common law, and legislative acts,(23) corporate capacity to acquire and alienate property,(24) and the necessity of a corporate seal to bind a corporation to a contract.