Wabash, St. Louis & Pacific Railway Co. v. Illinois

Last updated

Wabash, St. Louis & Pacific Railway Company v. Illinois
Seal of the United States Supreme Court.svg
Argued April 14–15, 1886
Decided October 25, 1886
Full case name Wabash, St. L. & P. Ry. Co. v. People of State of Illinois
Citations118 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
Chief Justice
Morrison Waite
Associate Justices
Samuel F. Miller  · Stephen J. Field
Joseph P. Bradley  · John M. Harlan
William B. Woods  · Stanley Matthews
Horace Gray  · Samuel Blatchford
Case opinions
MajorityMiller, joined by Field, Harlan, Woods, Matthews, Blatchford
DissentBradley, 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.

Contents

The court

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

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).

Effects of decision

See also

Related Research Articles

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.

Santa Clara County v. Southern Pacific Railroad Company, 118 U.S. 394 (1886), is a corporate law case of the United States Supreme Court concerning taxation of railroad properties. The case is most notable for a headnote stating that the Equal Protection Clause of the Fourteenth Amendment grants constitutional protections to corporations.

<span class="mw-page-title-main">Morrison Waite</span> Chief justice of the United States from 1874 to 1888

Morrison Remick "Mott" Waite was an American attorney, jurist, and politician from Ohio who served as the seventh chief justice of the United States from 1874 until his death in 1888. During his tenure, the Waite Court took a narrow interpretation of federal authority related to laws and amendments that were enacted during the Reconstruction Era to expand the rights of freedmen and protect them from attacks by white supremacy groups such as the Ku Klux Klan.

<span class="mw-page-title-main">William Burnham Woods</span> US Supreme Court justice from 1881 to 1887

William Burnham Woods was an American jurist who served as an associate justice of the Supreme Court of the United States. An appointee of President Rutherford B. Hayes, he served from 1881 until 1887. He wrote the majority opinion in United States v. Harris, involving the constitutionality of the Ku Klux Klan Act, and Presser v. Illinois, involving the application of the Second Amendment to the states; both cases adopted a narrow interpretation of the Fourteenth Amendment. He dissented rarely and wrote mostly uncontroversial opinions, and he has been largely forgotten by history.

<span class="mw-page-title-main">Samuel Freeman Miller</span> US Supreme Court justice from 1862 to 1890

Samuel Freeman Miller was an American lawyer and physician who served as an associate justice of the U.S. Supreme Court from 1862 until his death in 1890 and who authored landmark opinions in United States v. Kagama and The Slaughterhouse Cases.

National Labor Relations Board v Jones & Laughlin Steel Corporation, 301 U.S. 1 (1937), was a United States Supreme Court case that upheld the constitutionality of the National Labor Relations Act of 1935, also known as the Wagner Act. The case represented a major expansion in the Court's interpretation of Congress's power under the Commerce Clause and effectively spelled the end to the Court's striking down of New Deal economic legislation.

The Granger Laws were a series of laws passed in several midwestern states of the United States, namely Minnesota, Iowa, Wisconsin, and Illinois, in the late 1860s and early 1870s. The Granger Laws were promoted primarily by a group of farmers known as The National Grange of the Order of Patrons of Husbandry. The main goal of the Granger was to regulate rising fare prices of railroad and grain elevator companies after the American Civil War. The laws, which upset major railroad companies, were a topic of much debate at the time and ended up leading to several important court cases, such as Munn v. Illinois and Wabash v. Illinois.

<span class="mw-page-title-main">Interstate Commerce Act of 1887</span> United States federal law

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.

<span class="mw-page-title-main">Lists of law clerks of the Supreme Court of the United States</span>

The lists of law clerks of the Supreme Court of the United States cover the law clerks who have assisted the justices of the Supreme Court of the United States in various capacities since the first one was hired by Justice Horace Gray in 1882. The list is divided into separate lists for each position in the Supreme Court.

Southern Pacific Company v. Arizona, 325 U.S. 761 (1945), was a United States Supreme Court case in which the Court held that the Arizona Train Limit Law of 1912, which prohibited passenger trains with more than fourteen cars and prohibited freight trains with more than seventy cars, placed an unconstitutional burden on interstate commerce. The Court held that the law imposed a burden far greater than necessary to achieve Arizona's legitimate interest in lowering the rate of train accidents. This case is part of the Court's so-called negative commerce clause jurisprudence.

Smyth v. Ames, 171 U.S. 361 (1898), also called The Maximum Freight Case, was an 1898 United States Supreme Court case. The Supreme Court voided a Nebraska railroad tariff law, declaring that it violated the Fourteenth Amendment to the United States Constitution in that it takes property without the due process of law. The Court defined the constitutional limits of governmental power to set railroad and utility rates by stating that regulated industries have the right to a "fair return". The ruling was later overturned in Federal Power Commission v. Hope Natural Gas Company (1944).

Bibb v. Navajo Freight Lines, Inc., 359 U.S. 520 (1959), is a United States Supreme Court case in which the Court held that the Illinois law requiring trucks to have unique mudguards was unconstitutional under the Commerce clause.

The Railroad Commission Cases, 116 U.S. 307 (1886), is a United States Supreme Court case concerning the power of states to set transportation charges of railroad companies. The Court held that the fixing of freight and passenger rates in railroad transportation was a permissible exercise of state police power.

<span class="mw-page-title-main">Waite Court</span> Period of the US Supreme Court from 1874 to 1888

The Waite Court refers to the Supreme Court of the United States from 1874 to 1888, when Morrison Waite served as the seventh Chief Justice of the United States. Waite succeeded Salmon P. Chase as Chief Justice after the latter's death. Waite served as Chief Justice until his death, at which point Melville Fuller was nominated and confirmed as Waite's successor.

North American Co. v. Securities and Exchange Commission, 327 U.S. 686 (1946), is a United States Supreme Court case holding that a Securities and Exchange Commission (SEC) order under the Public Utility Holding Company Act (PUHCA) directing a public utility holding company to divest its securities of all companies except for one electric company did not violate the Commerce Clause or the Fifth Amendment to the United States Constitution.

<span class="mw-page-title-main">White Court (justices)</span> Period of the US Supreme Court from 1910 to 1921

The White Court refers to the Supreme Court of the United States from 1910 to 1921, when Edward Douglass White served as the Chief Justice of the United States. White, who had been an associate justice since 1894, succeeded Melville Fuller as Chief Justice after Fuller's death, and White served as Chief Justice until his own death a decade later. He was the first sitting associate justice to be elevated to Chief justice in the Court's history. He was succeeded by the former president William Howard Taft.

<span class="mw-page-title-main">Fuller Court</span> Period of the US Supreme Court from 1888 to 1910

The Fuller Court refers to the Supreme Court of the United States from 1888 to 1910, when Melville Fuller served as the eighth Chief Justice of the United States. Fuller succeeded Morrison R. Waite as Chief Justice after the latter's death, and Fuller served as Chief Justice until his death, at which point Associate Justice Edward Douglass White was nominated and confirmed as Fuller's replacement.

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.

United States v. Wrightwood Dairy Co., 315 U.S. 110 (1942), was a major decision of the US Supreme Court upholding the Agricultural Marketing Agreement Act of 1937 as a valid use of Congress' authority under the Commerce Clause of the United States Constitution.

References

  1. Wabash, St. Louis & Pacific Railway Co. v. Illinois, 118 U.S. 557 (1886).