Southern Railway Company v. United States | |
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Argued March 9–10, 1911 Decided October 30, 1911 | |
Full case name | Southern Railway Company, Plaintiff in Error, v. United States |
Citations | 222 U.S. 20 ( more ) 32 S. Ct. 2; 56 L. Ed. 72; 1911 U.S. LEXIS 1875 |
Holding | |
The Court held that under the Commerce Clause, the U.S. Congress can regulate safety on intrastate rail traffic because there is a close and substantial connection to interstate traffic. | |
Court membership | |
| |
Case opinion | |
Majority | Van Devanter, joined by Unanimous |
Laws applied | |
Safety Appliance Act, Commerce Clause |
Southern Railway Company v. United States, 222 U.S. 20 (1911), was a decision by the United States Supreme Court which held that under the Commerce Clause, the U.S. Congress can regulate safety on intrastate rail traffic because there is a close and substantial connection to interstate traffic. [1]
Congress required all train cars to be equipped with couplers as a safety measure. Southern Railway argued that the requirement applied only to train cars crossing state lines, not to train cars that operated inside one state.
The Safety Appliance Act of March 2, 1893, 27 Stat. 531, c. 196:
The Commerce Clause is plenary to protect persons and property moving in interstate commerce from all danger. No matter the source or destination, Congress may require all vehicles moving on lanes of interstate commerce to be so equipped with safety devices to avoid danger to persons and property in interstate commerce.
The Interstate Commerce Commission (ICC) was a regulatory agency in the United States created by the Interstate Commerce Act of 1887. The agency's original purpose was to regulate railroads to ensure fair rates, to eliminate rate discrimination, and to regulate other aspects of common carriers, including interstate bus lines and telephone companies. Congress expanded ICC authority to regulate other modes of commerce beginning in 1906. Throughout the 20th century, several of ICC's authorities were transferred to other federal agencies. The ICC was abolished in 1995, and its remaining functions were transferred to the Surface Transportation Board.
Gibbons v. Ogden, 22 U.S. 1 (1824), was a landmark decision of the Supreme Court of the United States which held that the power to regulate interstate commerce, which is granted to the US Congress by the Commerce Clause of the US Constitution, encompasses the power to regulate navigation. The decision is credited with supporting the economic growth of the antebellum United States and the creation of national markets. Gibbons v. Ogden has since provided the basis for Congress' regulation of railroads, freeways and television and radio broadcasts.
The Dormant Commerce Clause, or Negative Commerce Clause, in American constitutional law, is a legal doctrine that courts in the United States have inferred from the Commerce Clause in Article I of the US Constitution. The primary focus of the doctrine is barring state protectionism. The Dormant Commerce Clause is used to prohibit state legislation that discriminates against, or unduly burdens, interstate or international commerce. Courts first determine whether a state regulation discriminates on its face against interstate commerce or whether it has the purpose or effect of discriminating against interstate commerce. If the statute is discriminatory, the state has the burden to justify both the local benefits flowing from the statute and to show the state has no other means of advancing the legitimate local purpose.
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The Commerce Clause describes an enumerated power listed in the United States Constitution. The clause states that the United States Congress shall have power "to regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes". Courts and commentators have tended to discuss each of these three areas of commerce as a separate power granted to Congress. It is common to see the individual components of the Commerce Clause referred to under specific terms: the Foreign Commerce Clause, the Interstate Commerce Clause, and the Indian Commerce Clause.
The Safety Appliance Act is a United States federal law that made air brakes and automatic couplers mandatory on all trains in the United States. It was enacted on March 2, 1893, and took effect in 1900, after a seven-year grace period. The act is credited with a sharp drop in accidents on American railroads in the early 20th century.
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Houston East & West Texas Railway Co. v. United States, 234 U.S. 342 (1914), also known as the Shreveport Rate Case, was a decision of the United States Supreme Court expanding the power of the Commerce Clause of the Constitution of the United States. Justice Hughes's majority opinion stated that the federal government's power to regulate interstate commerce also allowed it to regulate purely intrastate commerce in cases where control of the former was not possible without control of the latter. Because the Supreme Court consolidated several related appeals, they are sometimes collectively known as the "Shreveport Rate Cases" although the Supreme Court issued only one ruling.
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United States v. Florida East Coast Railway Co., 410 U.S. 224 (1973), was a case decided by the United States Supreme Court.
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Schlemmer v. Buffalo, Rochester & Pittsburgh Railway Co., 205 U.S. 1 (1907), was a cause of action for the death of the plaintiff's intestate, Adam M. Schlemmer, while trying to couple a shovel car to a caboose.
Tinsley v. Treat, 205 U.S. 20 (1907), was a case decided by the Supreme Court of the United States that found while an indictment in a removal proceeding constitutes prima facie evidence of probable cause, it is not conclusive, so evidence put forth by a defendant showing that no offense triable in the district to which removal is sought had been committed is admissible, and its exclusion is not mere error, but the denial of a right secured under the Federal Constitution.
Johnson v. Southern Pacific Co., 196 U.S. 1 (1904), was a case before the United States Supreme Court. It interpreted the words "any car" in the Railroad Safety Appliance Act, prohibiting common carriers moving interstate commerce from using any car that was not equipped with automatic couplers. In doing so, it overturned the Eighth Circuit in Johnson v. Southern P. Co., 117 F. 462
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Louisville, New Orleans & Texas Railway Co. v. Mississippi, 133 U.S. 587 (1890), was a case in which the Supreme Court of the United States upheld a Mississippi law that required railroads to racially segregate their passengers. The Court in Hall v. Decuir (1878) had struck down a similar Louisiana law on the grounds that it unreasonably interfered with Congress's power to regulate interstate commerce. A railroad challenged the Mississippi law on the same ground, arguing that it violated the Dormant Commerce Clause by burdening interstate commerce. The Supreme Court, dividing 7 to 2, disagreed. Writing for the majority, Justice David Josiah Brewer distinguished Hall on the basis that Mississippi's law, unlike Louisiana's, applied solely to intrastate commerce. Justices John Marshall Harlan and Joseph P. Bradley dissented. According to Harlan, the Mississippi law subjected all trains, including those involved in interstate commerce, to the segregation requirement. Finding no differences between the case and Hall, he voted to strike down the law.
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