Houston East & West Texas Railway Co. v. United States
January 01, 1970
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.
Houston, East & West Texas Railway Company and Houston & Shreveport Railroad Company et al., Appellants, v. United States, the Interstate Commerce Commission et al., No. 567, and Texas & Pacific Railway Company et al., Appellants, v. United States, the Interstate Commerce Commission et al., No. 568.
Congressional authority necessarily embraces the right to control operations in all matters having a close and substantial relation to interstate traffic, to the efficiency of interstate service, and to the maintenance of conditions under which interstate commerce may be conducted upon fair terms.
The Houston East and West Texas Railway Company managed an interstate railway line that ran through Dallas and Marshall, Texas (on the eastern border of Texas), and Shreveport, Louisiana. The freight shipping rates "on wagons" from Marshall to Dallas, a distance of 148 miles, was 36.8 cents, and the rate from Marshall to Shreveport, a distance of 42 miles, was 56 cents; the rates for other goods and from other points in Texas showed a similar imbalance. Shreveport competed with Dallas for shipments from East Texas, but the skewed price structure (mandated by the Texas Railroad Commission[1]), greatly favored shipments to and from Dallas over Shreveport. The Interstate Commerce Commission, acting on a complaint from the Railroad Commission of Louisiana,[2] found that "an unlawful and undue preference and advantage" was thereby given to the Texas cities,[3] ordered the company to change the rate structure to end discriminatory pricing.[4]
The Tenth Amendment reserves for the states or the people all powers not expressly delegated to the federal government.
The US Constitution gives Congress the power to regulate interstate commerce. The regulation of commerce that is completely within a state is not an enumerated power of the federal government. In effect, the Interstate Commerce Commission was attempting to set the rate that the railroad could charge from Dallas to Marshall, a section of rail line completely within the borders of Texas. The issue was thus whether "Congress is impotent to control the intrastate charges of an interstate carrier" or whether Congress could go further or if it was necessary to regulate interstate commerce.
Decisionedit
Associate Justice Charles Evans Hughes, writing for the majority, rejected the railroad's argument, finding that congressional authority "necessarily embraces the right to control... operations in all matters having a close and substantial relation to interstate traffic, to the efficiency of interstate service, and to the maintenance of conditions under which interstate commerce may be conducted upon fair terms."[5] Regulation of the intrastate line was a means to the end of regulating interstate commerce, and was therefore allowed.
Two justices, Lurton and Pitney, dissented without issuing a written opinion.[6]
Legacyedit
The Interstate Commerce Clause has been used to steadily expand the power of the federal government, as almost any aspect of life, especially after the industrial revolution, can in some way be related to interstate commerce. The Shreveport Rate Case was an early example of this expansion.
As a leading case in the ability of governments to regulate activities occurring only within single subdivisions, on the grounds that those activities affect regulation on a larger scale, the Shreveport Rate Cases have been cited in many subsequent rulings, both in the United States and in other countries.[7]
"Shreveport Rate Case Appealed". New York Times. May 23, 1913.
"Railroads. Regulation of Rates. Power of Interstate Commerce Commission over Intrastate Rates. 'Shreveport Rate Cases'". Harvard Law Review. 28 (1): 113. 1914. doi:10.2307/1326545. JSTOR 1326545.
"The March Of Events: The Supremacy Of Interstate Commerce". The World's Work: A History of Our Time. XLIV (2): 377–378. August 1914. Retrieved August 4, 2009.
Sheppard, John S. Jr. (1915). "Another Word about the Evolution of the Federal Regulation of Intrastate Rates and the Shreveport Rate Cases". Harvard Law Review. 28 (3): 294–298. doi:10.2307/1325682. JSTOR 1325682.
External linksedit
Works related to Houston, East & West Texas Railway Company v. United States at Wikisource
Text of Houston E. & W. T. Ry. Co. v. United States, 234U.S. 342 (1914) is available from:CourtListenerFindlawJustiaLibrary of Congress
January 01, 1970
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Houston East amp 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 Houston E amp W T Ry Co v United StatesSupreme Court of the United StatesArgued October 28 29 1913Decided June 8 1914Full case nameHouston East amp West Texas Railway Company and Houston amp Shreveport Railroad Company et al Appellants v United States the Interstate Commerce Commission et al No 567 and Texas amp Pacific Railway Company et al Appellants v United States the Interstate Commerce Commission et al No 568 Citations234 U S 342 more 34 S Ct 833 58 L Ed 1341HoldingCongressional authority necessarily embraces the right to control operations in all matters having a close and substantial relation to interstate traffic to the efficiency of interstate service and to the maintenance of conditions under which interstate commerce may be conducted upon fair terms Court membershipChief Justice Edward D White Associate Justices Joseph McKenna Oliver W Holmes Jr William R Day Horace H LurtonCharles E Hughes Willis Van DevanterJoseph R Lamar Mahlon PitneyCase opinionsMajorityHughesDissentLurton unwritten DissentPitney unwritten Contents 1 Background 2 Decision 3 Legacy 4 See also 5 References 6 Further reading 7 External linksBackground editThe Houston East and West Texas Railway Company managed an interstate railway line that ran through Dallas and Marshall Texas on the eastern border of Texas and Shreveport Louisiana The freight shipping rates on wagons from Marshall to Dallas a distance of 148 miles was 36 8 cents and the rate from Marshall to Shreveport a distance of 42 miles was 56 cents the rates for other goods and from other points in Texas showed a similar imbalance Shreveport competed with Dallas for shipments from East Texas but the skewed price structure mandated by the Texas Railroad Commission 1 greatly favored shipments to and from Dallas over Shreveport The Interstate Commerce Commission acting on a complaint from the Railroad Commission of Louisiana 2 found that an unlawful and undue preference and advantage was thereby given to the Texas cities 3 ordered the company to change the rate structure to end discriminatory pricing 4 The Tenth Amendment reserves for the states or the people all powers not expressly delegated to the federal government The US Constitution gives Congress the power to regulate interstate commerce The regulation of commerce that is completely within a state is not an enumerated power of the federal government In effect the Interstate Commerce Commission was attempting to set the rate that the railroad could charge from Dallas to Marshall a section of rail line completely within the borders of Texas The issue was thus whether Congress is impotent to control the intrastate charges of an interstate carrier or whether Congress could go further or if it was necessary to regulate interstate commerce Decision editAssociate Justice Charles Evans Hughes writing for the majority rejected the railroad s argument finding that congressional authority necessarily embraces the right to control operations in all matters having a close and substantial relation to interstate traffic to the efficiency of interstate service and to the maintenance of conditions under which interstate commerce may be conducted upon fair terms 5 Regulation of the intrastate line was a means to the end of regulating interstate commerce and was therefore allowed Two justices Lurton and Pitney dissented without issuing a written opinion 6 Legacy editThe Interstate Commerce Clause has been used to steadily expand the power of the federal government as almost any aspect of life especially after the industrial revolution can in some way be related to interstate commerce The Shreveport Rate Case was an early example of this expansion As a leading case in the ability of governments to regulate activities occurring only within single subdivisions on the grounds that those activities affect regulation on a larger scale the Shreveport Rate Cases have been cited in many subsequent rulings both in the United States and in other countries 7 See also editList of United States Supreme Court cases volume 234References edit Houston E amp W T Ry Co v United States 234 U S 342 346 47 1914 234 U S at 345 234 U S at 347 234 U S at 348 234 U S at 351 234 U S at 360 E g http vlex com search index query 5Blc query 5D citas 3A 28CITA LEY 20030320 29Further reading edit Shreveport Rate Case Appealed New York Times May 23 1913 Railroads Regulation of Rates Power of Interstate Commerce Commission over Intrastate Rates Shreveport Rate Cases Harvard Law Review 28 1 113 1914 doi 10 2307 1326545 JSTOR 1326545 The March Of Events The Supremacy Of Interstate Commerce The World s Work A History of Our Time XLIV 2 377 378 August 1914 Retrieved August 4 2009 Sheppard John S Jr 1915 Another Word about the Evolution of the Federal Regulation of Intrastate Rates and the Shreveport Rate Cases Harvard Law Review 28 3 294 298 doi 10 2307 1325682 JSTOR 1325682 External links edit nbsp Works related to Houston East amp West Texas Railway Company v United States at Wikisource Text of Houston E amp W T Ry Co v United States 234 U S 342 1914 is available from CourtListener Findlaw Justia Library of Congress Retrieved from https en wikipedia org w index php title Houston East 26 West Texas Railway Co v United States amp oldid 1190613545, wikipedia, wiki, book, books, library,
