Southern Pacific Terminal Co. v. ICC

Last updated

Southern Pacific Terminal Co. v. ICC
Seal of the United States Supreme Court.svg
Argued December 9, 1910
Decided February 20, 1911
Full case nameSouthern Pacific Terminal Co. v. Interstate Commerce Commission
Citations219 U.S. 498 ( more )
31 S. Ct. 279; 55 L. Ed. 310; 1911 U.S. LEXIS 1650
Case history
PriorAppeal from the Circuit Court of the United States for the Southern District of Texas
Court membership
Chief Justice
Edward D. White
Associate Justices
John M. Harlan  · Joseph McKenna
Oliver W. Holmes Jr.  · William R. Day
Horace H. Lurton  · Charles E. Hughes
Willis Van Devanter  · Joseph R. Lamar
Case opinion
MajorityMcKenna, joined by unanimous
Laws applied
U.S. Const.

Southern Pacific Terminal Co. v. ICC, 219 U.S. 498 (1911), was a United States Supreme Court decision that held that while normally, in order for the court to hear a case, there must still be a controversy outstanding, when the issue was such that it would be of short duration, and would most likely become moot before appellate review could take place, and that the issue was likely to reoccur, then the court could hear the issue. [1]

Contents

Issue

A division of the Southern Pacific Railroad was aiding a cottonseed exporter in the Port of Galveston by negotiating discount wharf fees on his behalf in exchange for requiring farmers to haul the crop exclusively in Southern Pacific railcars. When the Interstate Commerce Commission challenged the arrangement as anti-competitive, the contract was terminated but the ICC felt similar product tying would reoccur once the case was dismissed as moot.

The court's decision

The court referred to this condition as,

The case is not moot where interests of a public character are asserted by the Government under conditions that may be immediately repeated, merely because the particular order involved has expired... The rule that this court will only determine actual controversies, and will dismiss if events have transpired pending appeal which render it impossible to grant the appellant effectual relief does not apply to an appeal involving [a government] order .. merely because that order has expired. Such orders are usually continuing and capable of repetition, and their consideration, and the determination of the right of the Government and the carriers to redress, should not be defeated on account of the shortness of their term.

This condition, known as "capable of repetition, yet evading review," [2] has allowed the court to take cases which it otherwise would be unable to decide upon, because the appellant would otherwise have no grounds to appeal. This issue has become important in a number of areas including First Amendment cases involving press coverage of trials, [3] and to statutes involving abortion. [4]

See also

Related Research Articles

<span class="mw-page-title-main">Mootness</span> Legal term on the status of a matter

The terms moot, mootness and moot point are used in both in English and American law, although with different meanings.

<span class="mw-page-title-main">Interstate Commerce Commission</span> Defunct United States federal regulatory agency (1887-1996)

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.

<span class="mw-page-title-main">Judicial functions of the House of Lords</span> Historical judicial role of the UK House of Lords

Whilst the House of Lords of the United Kingdom is the upper chamber of Parliament and has government ministers, for many centuries it had a judicial function. It functioned as a court of first instance for the trials of peers and for impeachments, and as a court of last resort in the United Kingdom and prior, the Kingdom of Great Britain and the Kingdom of England.

<span class="mw-page-title-main">Chicago, Rock Island and Pacific Railroad</span> Defunct American Class I railway

The Chicago, Rock Island and Pacific Railroad was an American Class I railroad. It was also known as the Rock Island Line, or, in its final years, The Rock.

Moot court is a co-curricular activity at many law schools. Participants take part in simulated court or arbitration proceedings, usually involving drafting memorials or memoranda and participating in oral argument. In many countries, the phrase "moot court" may be shortened to simply "moot" or "mooting". Participants are either referred to as "mooters" or, less conventionally, "mooties".

Justiciability concerns the limits upon legal issues over which a court can exercise its judicial authority. It includes, but is not limited to, the legal concept of standing, which is used to determine if the party bringing the suit is a party appropriate to establishing whether an actual adversarial issue exists. Essentially, justiciability seeks to address whether a court possesses the ability to provide adequate resolution of the dispute; where a court believes that it cannot offer such a final determination, the matter is not justiciable.

Interstate Commerce Commission v. Cincinnati, New Orleans and Texas Pacific Railway Co., 167 U.S. 479 (1897), was an important early U.S. Supreme Court case in the development of American administrative law.

<span class="mw-page-title-main">Case or Controversy Clause</span> Clause of the U.S. Constitution regarding judicial review

The Supreme Court of the United States has interpreted the Case or Controversy Clause of Article III of the United States Constitution as embodying two distinct limitations on exercise of judicial review: a bar on the issuance of advisory opinions, and a requirement that parties must have standing.

The Court of Appeals of Virginia, established January 1, 1985, is an intermediate appellate court of 17 judges that hears appeals from decisions of Virginia's circuit courts and the Virginia Workers' Compensation Commission. The Court sits in panels of at least three judges, and sometimes hears cases en banc. Appeals from the Court of Appeals go to the Supreme Court of Virginia.

Richard John Baker v. Gerald R. Nelson, 291 Minn. 310, 191 N.W.2d 185 (1971), was a case in which the Minnesota Supreme Court decided that construing a marriage statute to restrict marriage licenses to persons of the opposite sex "does not offend" the U.S. Constitution. Baker appealed the decision, and on October 10, 1972, the U.S. Supreme Court dismissed the appeal "for want of a substantial federal question".

<i>R v Mercure</i> Supreme Court of Canada case

R v Mercure was a ruling by the Supreme Court of Canada in 1988, dealing with language rights in the province of Saskatchewan.

Ware & Leland v. Mobile County, 209 U.S. 405 (1908), is a case in which the United States Supreme Court held that contracts for the sales of cotton for future delivery that do not oblige interstate shipments are not subjects of interstate commerce. The Court also held that a state tax on persons engaged in buying and selling cotton for future delivery was not a regulation of interstate commerce, and that the imposition of the tax was not beyond the power of the state.

Davis v. Federal Election Commission, 554 U.S. 724 (2008), is a decision by the Supreme Court of the United States which held that section 319 of the Bipartisan Campaign Reform Act of 2002 unconstitutionally infringed on candidates' rights as provided by First Amendment.

Hartsville Oil Mill v. United States, 271 U.S. 43 (1926), is a United States Supreme Court case in which the Court held that the jurisdiction of the Court of Claims was not enlarged by Congressional reference legislation when the court already had jurisdiction to hear the case under another section of the Judicial Code. Additionally the court held that modification to the contract in question was not by duress as there had not been an inadequate power in the courts to remedy the effects of the threatened actions.

<i>Cardona v. Shinseki</i>

Cardona v. Shinseki was an appeal brought in the United States Court of Appeals for Veterans Claims (CAVC) of a decision by the Board of Veterans' Appeals upholding the denial of service-connected disability benefits for the dependent wife of a female veteran. The United States Department of Veterans Affairs denied the disability benefits based on the definition of "spouse" as "a person of the opposite sex" under federal statute. On March 11, 2014, the CAVC dismissed the case as moot after the Secretary of Veterans Affairs advised the Court that he would neither defend nor enforce the federal statute. Cardona subsequently received full payment of her spousal benefits, retroactive to her date of application.

Microsoft Corp. v. United States, known on appeal to the U.S. Supreme Court as United States v. Microsoft Corp., 584 U.S. ___, 138 S. Ct. 1186 (2018), was a data privacy case involving the extraterritoriality of law enforcement seeking electronic data under the 1986 Stored Communications Act (SCA), Title II of the Electronic Communications Privacy Act of 1986 (ECPA), in light of modern computing and Internet technologies such as data centers and cloud storage.

Association for Molecular Pathology v. Myriad Genetics, Inc., 569 U.S. 576 (2013), was a Supreme Court case, which decided that "a naturally occurring DNA segment is a product of nature and not patent eligible merely because it has been isolated.” However, as a "bizarre conciliatory prize" the Court allowed patenting of complementary DNA, which contains exactly the same protein-coding base pair sequence as the natural DNA, albeit with introns removed.

Railway Labor Executives' Association v. Gibbons, 455 U.S. 457 (1982), was a U.S. Supreme Court case that affirmed distinction between the Commerce Clause and Bankruptcy Clause of the Enumerated powers, and held that legislation passed by Congress regarding bankruptcy must respect the uniformity requirement by not targeting a specific company.

<i>N.V.H v Minister for Justice & Equality</i> Irish Supreme Court case

N.H.V. v Minister for Justice & Equality [2017] IESC 35 was an Irish Supreme Court case in which the Court upheld a challenge to the absolute prohibition on employment of asylum seekers contained in Section 9(4) of the Refugee Act 1996 and held it to be contrary to the constitutional right to seek employment.

Uzuegbunam v. Preczewski, 592 U.S. ___ (2021), is a decision by the Supreme Court of the United States, dealing with nominal damages to be awarded to individuals whose right to freedom of speech has been suppressed by an entity but subsequently rendered moot due to intervening circumstances. In an 8–1 decision, the Court held that such nominal damages satisfy the Article Three requirement of redressability, when awarded for a past violation of a legal rights.

References

  1. Southern Pacific Terminal Co. v. ICC, 219 U.S. 498 (1911).
  2. 219 U.S. at 515.
  3. Richmond Newspapers, Inc. v. Virginia , 448 U.S. 555 (1980).
  4. Roe v. Wade , 410 U.S. 113 (1973).