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Wolcott v. Des Moines Company

1866 • 72 U.S. 681 • Chase Court
In the case of Wolcott v. Des Moines Company, the Supreme Court ruled in favor of Wolcott. The dispute arose when a company called Des Moines Navigation and Railroad Company was formed to build a railroad from Keokuk, Iowa to Council Bluffs, Iowa. At that time, there were two bridges over the Mississippi River at Keokuk: one owned by John B. Wolcott and another owned by William Hoxie & Co., which had been built with permission from Congress but without payment for use of land or water rights...Open Case
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Chief Chase Court
Term: 1866
72 U.S. 681
18 L. Ed. 689
1866 U.S. LEXIS 971

Wolcott v. Des Moines Company

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Opinion Summary
AI Abstract

In the case of Wolcott v. Des Moines Company, the Supreme Court ruled in favor of Wolcott. The dispute arose when a company called Des Moines Navigation and Railroad Company was formed to build a railroad from Keokuk, Iowa to Council Bluffs, Iowa. At that time, there were two bridges over the Mississippi River at Keokuk: one owned by John B. Wolcott and another owned by William Hoxie & Co., which had been built with permission from Congress but without payment for use of land or water rights granted by state law. When Des Moines attempted to construct its own bridge across the river near these existing ones, both owners sued for damages due to interference with their respective businesses caused by this new construction project. The Supreme Court found in favor of Mr. Wolcott on grounds that his property rights had been violated as he did not receive any compensation for allowing access through his bridge or waterway; furthermore it was determined that such an act constituted an illegal taking under state law since no payment had been made prior to construction beginning on the new bridge project initiated by Des Moines Navigation and Railroad Company .

Dissent Summary
AI Abstract

In the case of Wolcott v. Des Moines Company, the Supreme Court was asked to decide whether a state law that allowed for an increase in wages violated the Thirteenth Amendment's prohibition against involuntary servitude. The majority opinion held that it did not violate this amendment because it only applied to those who voluntarily entered into contracts with employers and thus could not be considered involuntary servitude. However, Justice Field dissented from this opinion and argued that any form of compulsion or coercion by an employer over their employees should be considered as a violation of the Thirteenth Amendment regardless if they had agreed to enter into contract with them or not. He further stated that such laws were oppressive and unjustified since they deprived workers of their right to freely negotiate wages without interference from government legislation. In conclusion, Justice Field believed that any form of wage regulation imposed by states on employers would constitute a violation of the Thirteenth Amendment’s ban on involuntary servitude even if there was voluntary agreement between both parties involved in labor contracts.

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