Due to a chronic freight car shortage, Congress had enlarged the scope of the Interstate Commerce Commission's authority to prescribe per diem rate charges for the use of one company's freight car by another, thus giving an incentive to each company to use the cars more efficiently or to acquire more freight cars. The Commission, in passing the regulation, had allowed railroads 60 days to file statements of position on the matter. The Commission had said: "that any party requesting oral hearing shall set forth with specificity the need therefore and the evidence to be adduced." Several railroads filed statements requesting oral hearings, but the Commission did not hold further hearings and overruled the requests.
Two railroad companies brought an action in the Middle District of Florida to set aside the per diem rates that had been established because they had only been allowed to make written submissions during "hearings" for the proposed rule and not oral arguments. The District Court found that the Interstate Commerce Act required that the Interstate Commerce Commission act in accordance with Administrative Procedure Act, 5 U.S.C. Sec. 556(d), which required that parties would not be "prejudiced" by an agency's decision to receive all submissions of evidence in written form.
The Supreme Court reversed the District Court's decision. Justice Rehnquist delivered the opinion, explaining that Section 1(14)(a) of the Interstate Commerce Act which had enlarged the Commission's authority to pass regulations "after hearing" was not a requirement that the ICC allow oral arguments in its rulemaking proceedings and that the hearing requirement had been met.
The Court distinguished between administrative rulemaking and administrative adjudications. Since there had been no effort to single out a particular railroad, the court found the agency's action was of a basically legislative type judgment as opposed to an adjudication which could entail due process hearing rights.
The Court referred to its decision in Bi-Metallic Investment Co. v. State Board of Equalization in which it held that no hearing at all was constitutionally required prior to a decision by state tax officers in Colorado to increase the valuation of all taxable property in Denver by a substantial amount.
Justice Douglas joined by Justice Stewart dissented finding that the Railroads had not been afforded hearings guaranteed by Section 1(14)(a) of the Interstate Commerce Act and 5 U.S.C. Sections 553, 556, and 557.
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.
The Federal Trade Commission Act of 1914 is a United States federal law which established the Federal Trade Commission. The Act was signed into law by US President Woodrow Wilson in 1914 and outlaws unfair methods of competition and unfair acts or practices that affect commerce.
A court of record is a trial court or appellate court in which a record of the proceedings is captured and preserved, for the possibility of appeal. A court clerk or a court reporter takes down a record of oral proceedings. That written record is preserved at least long enough for all appeals to be exhausted, or for some further period of time provided by law.
The Surface Transportation Board (STB) of the United States is an independent federal agency that serves as an adjudicatory board. The board was created in 1996 following the abolition of the Interstate Commerce Commission (ICC), and absorbed regulatory powers relevant to the railroad industry previously under the ICC's purview.
In administrative law, rulemaking is the process that executive and independent agencies use to create, or promulgate, regulations. In general, legislatures first set broad policy mandates by passing statutes, then agencies create more detailed regulations through rulemaking.
An administrative law judge (ALJ) in the United States is a judge and trier of fact who both presides over trials and adjudicates claims or disputes involving administrative law. ALJs can administer oaths, take testimony, rule on questions of evidence, and make factual and legal determinations.
United States federal administrative law encompasses statutes, regulations, rules, common law rulings, and directives issued by the Office of Information and Regulatory Affairs in the Executive Office of the President, that together define the extent of powers and responsibilities held by administrative agencies of the United States government. The executive, legislative, and judicial branches of the U.S. federal government cannot always directly perform their constitutional responsibilities. Specialized powers are therefore delegated to an agency, board, or commission. These administrative governmental bodies oversee and monitor activities in complex areas, such as commercial aviation, medical device manufacturing, and securities markets.
The Interstate Commerce Act of 1887 is a United States federal law that was designed to regulate the railroad industry, particularly its monopolistic practices. The Act required that railroad rates be "reasonable and just," but did not empower the government to fix specific rates. It also required that railroads publicize shipping rates and prohibited short haul or long haul fare discrimination, a form of price discrimination against smaller markets, particularly farmers in Western or Southern Territory compared to the official Eastern states. The Act created a federal regulatory agency, the Interstate Commerce Commission (ICC), which it charged with monitoring railroads to ensure that they complied with the new regulations.
The Supreme Court of the United States is the highest court in the federal judiciary of the United States. The procedures of the Court are governed by the U.S. Constitution, various federal statutes, and its own internal rules. Since 1869, the Court has consisted of one chief justice and eight associate justices. Justices are nominated by the president, and with the advice and consent (confirmation) of the U.S. Senate, appointed to the Court by the president. Once appointed, justices have lifetime tenure unless they resign, retire, or are removed from office.
United States v. Interstate Commerce Commission, 337 U.S. 426 (1949), is a decision of the Supreme Court of the United States addressing several issues, including the judicial standard of one party's inability to sue itself, the ability of the United States government specifically to sue federally affiliated departments, and the ability of courts to determine legislative intent. While this decision did not have many broad implications, it did offer a more "common-sense" understanding of determining what constitutes a justiciable controversy.
Richardson v. Perales, 402 U.S. 389 (1971), was a case heard by the United States Supreme Court to determine and delineate several questions concerning administrative procedure in Social Security disability cases. Among the questions considered was the propriety of using physicians' written reports generated from medical examinations of a disability claimant, and whether these could constitute "substantial evidence" supportive of finding nondisability under the Social Security Act.
Heckler v. Chaney, 470 U.S. 821 (1985), was a United States Supreme Court decision that held agency decisions to not undertake enforcement proceedings is "committed to agency discretion by law" and therefore not subject to judicial review under the Administrative Procedure Act.
United States v. Students Challenging Regulatory Agency Procedures (SCRAP), 412 U.S. 669 (1973), was a landmark decision of the United States Supreme Court in which the Court held that the members of SCRAP—five law students from the George Washington University Law School—had standing to sue under Article III of the Constitution to challenge a nationwide railroad freight rate increase approved by the Interstate Commerce Commission (ICC). SCRAP was the first full-court consideration of the National Environmental Policy Act (NEPA). The Court also reversed the lower court decision that an injunction should be issued at the suspension stage of the ICC rate proceeding. The standing decision has retained its place as the high mark in the Court's standing jurisprudence.
Sarah Keys v. Carolina Coach Company, 64 MCC 769 (1955) is a landmark civil rights case in the United States in which the Interstate Commerce Commission, in response to a bus segregation complaint filed in 1953 by a Women's Army Corps (WAC) private named Sarah Louise Keys, broke with its historic adherence to the Plessy v. Ferguson separate but equal doctrine and interpreted the non-discrimination language of the Interstate Commerce Act as banning the segregation of black passengers in buses traveling across state lines.
Glidden Co. v. Zdanok, 370 U.S. 530 (1962), is a United States Supreme Court case in which the Court held that judges of the Court of Claims and the Court of Customs and Patent Appeals were judges created under Article III of the Constitution. As such, it was permissible for the Chief Justice of the United States under 28 U.S.C. § 293(a) to designate judges from the Court of Claims and the Court of Customs and Patent Appeals to serve on district courts and courts of appeals.
The Administrative Procedure Act (APA), Pub. L.Tooltip Public Law 79–404, 60 Stat. 237, enacted June 11, 1946, is the United States federal statute that governs the way in which administrative agencies of the federal government of the United States may propose and establish regulations, and it grants U.S. federal courts oversight over all agency actions. According to Hickman & Pierce, it is one of the most important pieces of United States administrative law, and serves as a sort of "constitution" for U.S. administrative law.
Baltimore Gas & Electric Co. v. Natural Resources Defense Council, Inc., 462 U.S. 87 (1983), is a United States Supreme Court decision that held valid a Nuclear Regulatory Commission (NRC) rule that during the licensing of nuclear power plants, the permanent storage of nuclear waste should be assumed to have no environmental impact.
Contested case hearing is the name for quasi-judicial administrative hearings governed by state law. State agencies that make decisions that could affect people's "rights, duties, and privileges" must have a process for holding contested case hearings. The purpose of these hearings is to provide the decision-makers with the most complete and relevant information they need to make a proper decision. These hearings are like an informal court proceeding. They have three parts:
United Gas Pipe Line Co. v. Ideal Cement Co., 369 U.S. 134 (1962), is a United States Supreme Court case which vacated a lower appellate court decision, holding that federal courts should abstain from ruling on the constitutionality of a state tax issue that state courts should determine.
Bowen v. Georgetown University Hospital, 488 U.S. 204 (1988), was a case in which the United States Supreme Court held that agencies should not be presumed to have the power to promulgate retroactive rules unless that power is expressly authorized by Congress. Justice Anthony Kennedy wrote for a unanimous court that the Secretary of Health and Human Services had exceeded his rulemaking authority under the Medicare Act in promulgating a wage index rule in 1984 under which he would recoup Medicare reimbursements paid to hospitals, including Georgetown University Hospital, that had been disbursed since 1981 according to the pre-1984 rule. Justice Antonin Scalia concurred in the judgment, writing separately that, in addition to the particular language of the Medicare Act, the Administrative Procedure Act more broadly prohibits retroactive rulemaking because it defines rules as having exclusively future effect, as opposed to adjudicative orders.
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