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Memphis & Little Rock Railroad Company v. Railroad Commissioners

• 1884 • 112 U.S. 609 • Waite Court
This case was a dispute between the Memphis & Little Rock Railroad Company and the Railroad Commissioners of Arkansas. The Railroad Company argued that the Commissioners had no authority to regulate the rates of freight and passenger traffic on the Company's railroad. The Commissioners argued that they had the authority to regulate the rates under the Arkansas Constitution. The Supreme Court held that the Commissioners did have the authority to regulate the rates of freight and passenger...Open Case
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Chief Waite Court
Term: 1884
Docket: 859
112 U.S. 609
5 S. Ct. 299
28 L. Ed. 837
1884 U.S. LEXIS 1930

Memphis & Little Rock Railroad Company v. Railroad Commissioners

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Opinion Summary
AI Abstract

This case was a dispute between the Memphis & Little Rock Railroad Company and the Railroad Commissioners of Arkansas. The Railroad Company argued that the Commissioners had no authority to regulate the rates of freight and passenger traffic on the Company's railroad. The Commissioners argued that they had the authority to regulate the rates under the Arkansas Constitution. The Supreme Court held that the Commissioners did have the authority to regulate the rates of freight and passenger traffic on the Company's railroad. The Court reasoned that the Arkansas Constitution gave the Commissioners the power to regulate the rates of freight and passenger traffic on all railroads in the state. The Court also held that the Commissioners had the authority to set reasonable rates for the transportation of freight and passengers. The Court concluded that the Commissioners had the authority to regulate the rates of freight and passenger traffic on the Company's railroad and that the rates set by the Commissioners were reasonable. The Court also held that the Company was not entitled to any compensation for the rates set by the Commissioners.

Dissent Summary
AI Abstract

In Memphis & Little Rock Railroad Company v. Railroad Commissioners, the Supreme Court was asked to decide whether a state law that set maximum rates for railroads violated the Fourteenth Amendment's Due Process Clause. Justice Field wrote a dissenting opinion in which he argued that states have an inherent right to regulate their own internal commerce and should not be subject to federal interference unless there is clear evidence of abuse or fraud. He further asserted that while it may be true that some railroad companies are being treated unfairly by certain state laws, this does not mean all such regulations must be struck down as unconstitutional. Instead, he suggested allowing each case to stand on its merits and determining if any particular regulation violates due process rights on an individual basis rather than making sweeping generalizations about all similar laws across the country.

Opinion written by Justice SMatthews
Decided: Dec 22, 1884
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