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Railroad Company v. Dubois was a United States Supreme Court case that was decided in 1870. The case involved a dispute between the Railroad Company and Dubois, a farmer, over the right of way of a railroad. Dubois had been granted a right of way by the state of Illinois, but the Railroad Company argued that the right of way was invalid because it had not been approved by the federal government. The Supreme Court ruled in favor of the Railroad Company, holding that the right of way granted by the state of Illinois was invalid because it had not been approved by the federal government. The Court reasoned that the federal government had exclusive authority over interstate commerce, and that the right of way granted by the state was in conflict with the federal government's authority. The Court also held that the Railroad Company had the right to use the right of way, as long as it did not interfere with the rights of other landowners. The decision in Railroad Company v. Dubois established the principle that the federal government has exclusive authority over interstate commerce, and that the states cannot grant rights of way that conflict with federal law. This decision has been cited in numerous cases since then, and has been used to support the federal government's authority over interstate commerce.
In the case of Railroad Company v. Dubois, Justice Field delivered a dissenting opinion in which he argued that the majority's decision was wrongfully decided and should be reversed. He stated that Congress had not intended to grant railroad companies immunity from liability for injuries caused by their negligence when it passed the Federal Employers' Liability Act (FELA). The FELA was created to protect employees who were injured while working on railroads, but did not provide any protection against negligent acts committed by those same employers. Therefore, Justice Field concluded that since there was no evidence of congressional intent to immunize railroad companies from liability under FELA, Dubois should have been allowed to pursue his claim against the company for damages resulting from its negligence. Furthermore, he argued that if Congress wanted such an exemption they would have explicitly included it in the text of FELA or some other statute granting immunity to employers like this one.