What Was the Primary Result of the 1909 Landmark Case

What was the primary result of the 1909 landmark case of New York Central Railroad v. United States?

A) that because corporations were not physical beings, they could not be held liable for crimes
B) that corporations could be held accountable for crimes of intent committed by its agents
C) that corporations had no mind and therefore could not establish the mens rea necessary to be held accountable
D) that corporations were protected by federal statutes from being prosecuted for crimes that require mens rea