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United States v. Des Moines Navigation And Railway Company

• 1891 • 142 U.S. 510 • Fuller Court
In the United States v. Des Moines Navigation and Railway Company case of 1891, the Supreme Court ruled in favor of the U.S. government, asserting its right to regulate interstate commerce over navigable waterways. The dispute arose when Des Moines Navigation and Railway Company began constructing a bridge across the Des Moines River without obtaining Congressional approval first. The company argued that since both ends of their proposed bridge were within Iowa state lines, it was an intrastate...Open Case
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Chief Fuller Court
Term: 1891
Docket: 987
142 U.S. 510
12 S. Ct. 308
35 L. Ed. 1099
1892 U.S. LEXIS 1989
Argued: Nov 18, 1891

United States v. Des Moines Navigation And Railway Company

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Opinion Summary
AI Abstract

In the United States v. Des Moines Navigation and Railway Company case of 1891, the Supreme Court ruled in favor of the U.S. government, asserting its right to regulate interstate commerce over navigable waterways. The dispute arose when Des Moines Navigation and Railway Company began constructing a bridge across the Des Moines River without obtaining Congressional approval first. The company argued that since both ends of their proposed bridge were within Iowa state lines, it was an intrastate matter rather than an interstate one; hence they did not require federal permission for construction. However, the court held that because rivers like Des Moines are considered highways for trade and transportation between different states (interstate commerce), any obstruction or alteration to them falls under federal jurisdiction as per Article I Section 8 Clause 3 (the Commerce Clause) of US Constitution which gives Congress power "To regulate Commerce with foreign Nations, among several States". Therefore, even though physically located entirely within one state's boundaries such obstructions could affect other states' interests too by impeding navigation on these waterways. The decision reaffirmed Federal Government’s authority over all navigable waters in U.S., regardless if they lie completely within a single state or cross multiple ones - thereby setting important precedent for future cases involving similar issues about control over natural resources & infrastructure development projects affecting them.

Dissent Summary
AI Abstract

In the dissenting opinion for United States v. Des Moines Navigation and Railway Company, it was argued that the government did not have a valid claim to ownership of the riverbed in question. The dissenters believed that when Iowa became a state, it gained all rights to its navigable waters and their beds, even if they had been previously granted by Congress to another entity. They contended that any such grant made before statehood would be voided upon admission into the Union because sovereignty over these lands should belong solely to each individual state under principles of federalism. Therefore, according to this view, since Iowa had become a state prior to Congress's grant of land for railway construction purposes (which included part of the riverbed), those lands should have reverted back automatically from federal control or ownership directly into Iowa's possession at that time.

Opinion written by Justice DJBrewer
Decided: Jan 11, 1892
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