Chicago, Milwaukee & St. Paul Railway Co. v. Minnesota

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Chicago, Milwaukee & St. Paul Railway Company v. Minnesota
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Argued January 13–14, 1890
Decided March 24, 1890
Full case name Chicago, Milwaukee, St. Paul and Pacific Railroad Company v. State of Minnesota ex rel. Railroad and Warehouse Commission
Citations134 U.S. 418 ( more )
10 S. Ct. 462; 33 L. Ed. 970; 1890 U.S. LEXIS 1984
Holding
Procedural due process applies to state regulatory action.
Court membership
Chief Justice
Melville Fuller
Associate Justices
Samuel F. Miller  · Stephen J. Field
Joseph P. Bradley  · John M. Harlan
Horace Gray  · Samuel Blatchford
Lucius Q. C. Lamar II  · David J. Brewer
Case opinions
MajorityBlatchford, joined by Fuller, Field, Harlan, Brewer
ConcurrenceMiller
DissentBradley, joined by Gray, Lamar

Chicago, Milwaukee & St. Paul Railway Company v. Minnesota, 134 U.S. 418 (1890), was a case in which the Supreme Court of the United States held that procedural due process limits state regulatory power over railroad rates. [1] A regulatory agency in Minnesota had set railroad rates that the Minnesota Supreme Court had refused to overturn. When the Chicago, Milwaukee, St. Paul and Pacific Railroad appealed the case, the U.S. Supreme Court found that the rates were set without due process of law, specifically without an opportunity to challenge the equality and reasonableness of the charges. The Minnesota court had sanctioned rate-setting without any judicial hearing, requirement of notice or witnesses, "-in fact, nothing which has the semblance of due process of law". [2]

Supreme Court of the United States Highest court in the United States

The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all federal and state court cases that involve a point of federal law, and original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. The Court holds the power of judicial review, the ability to invalidate a statute for violating a provision of the U.S. Constitution. It is also able to strike down presidential directives for violating either the Constitution or statutory law. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The Court may decide cases having political overtones, but it has ruled that it does not have power to decide non-justiciable political questions.

Due process is the legal requirement that the state must respect all legal rights that are owed to a person. Due process balances the power of law of the land and protects the individual person from it. When a government harms a person without following the exact course of the law, this constitutes a due process violation, which offends the rule of law.

Minnesota Supreme Court the highest court in the U.S. state of Minnesota

The Minnesota Supreme Court is the highest court in the U.S. state of Minnesota. The court hears cases in the Supreme Court chamber in the Minnesota State Capitol or in the nearby Minnesota Judicial Center.

Contents

The court rejected the railroad's argument that the state's contract with the Minnesota railroad line, as it existed in prior state-chartered companies that the railroad later bought, remained in force against state law. Instead, they found that the state's right to regulate industry could not be forfeited except by an explicit declaration in law. However, this issue was subsumed by the court's broader decision regarding due process.

Justice Bradley dissented from the decision, arguing that it practically overturned Munn v. Illinois and other railroad cases that left states to decide toll rates. He indicated that it was the province of the states to decide the policy question of railroad rates, and not that of the judiciary.

Munn v. Illinois, 94 U.S. 113 (1876), was a United States Supreme Court case in which the Court upheld the power of state governments to regulate private industries that affect "the common good".

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References

  1. Chicago, Milwaukee & St. Paul Railway Co. v. Minnesota, 134 U.S. 418 (1890).
  2. 134 U.S. at 457.
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