Wabash, St. Louis & Pacific Railway Company v. Illinois | |
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Argued April 14–15, 1886 Decided October 25, 1886 | |
Full case name | Wabash, St. L. & P. Ry. Co. v. People of State of Illinois |
Citations | 118 U.S. 557 ( more ) 7 S. Ct. 4; 30 L. Ed. 244 |
Holding | |
The Court held that Illinois had violated the Commerce Clause by placing a direct burden on interstate commerce. Under the Commerce Clause only Congress had the power to do so and states could only place indirect burdens on commerce. | |
Court membership | |
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Case opinions | |
Majority | Miller, joined by Field, Harlan, Woods, Matthews, Blatchford |
Dissent | Bradley, joined by Waite, Gray |
Laws applied | |
U.S. Const. amend. XIV | |
This case overturned a previous ruling or rulings | |
Munn v. Illinois (1877) |
Wabash, St. Louis & Pacific Railway Company v. Illinois, 118 U.S. 557 (1886), also known as the Wabash Case, was a Supreme Court decision that severely limited the rights of states to control or impede interstate commerce. It led to the creation of the Interstate Commerce Commission.
The majority's opinion was written by Justice Samuel Miller; joining him were associate justices Stephen Field, John Harlan, William Woods, Stanley Matthews, and Samuel Blatchford. Dissenting were Chief Justice Morrison Waite and associate justices Joseph Bradley and Horace Gray. [1]
The case was argued on April 14, 1886 - April 15, 1886 and was decided on October 25, 1886, by vote of 6 to 3. Associate Justice Miller wrote for the Court with Associate Justices Field, Harlan, Woods, Matthews, and Blatchford concurring; Associate Justices Bradley and Gray, along with Chief Justice Waite, dissented.
In Wabash, "direct" burdens on interstate commerce were not permitted by the Export Tax Clause of the Constitution (Article I, Section 9); however, those "indirect" burdens were permitted under the Commerce Clause. This was a standard enacted in Cooley v. Board of Wardens (1852).
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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