Appellants
South Carolina State Highway Department, et al.
Appellees
Barnwell Bros., Inc. et al.
Appellants' Claim
That South Carolina restrictions on the weight and width of trucks did not violate the Commerce Clause of the Constitution.
Chief Lawyers for Appellants
Steve C. Griffith, Thomas W. Davis, and Eugene S. Blease
Chief Lawyers for Appellees
S. King Funkhouser and Frank Coleman
Justices for the Court
Hugo Lafayette Black, Louis D. Brandeis, Pierce Butler, Charles Evans Hughes,James Clark McReynolds, Owen Josephus Roberts, Harlan Fiske Stone (writing for the Court)
Justices Dissenting
None (Benjamin N. Cardozo and Stanley Forman Reed did not participate)
Place
Washington, D.C.
Date of Decision
14 February 1938
Decision
Found for the appellants, reversing the lower court's order to enjoin enforcement of the state regulations.
Significance
The Court reaffirmed that if Congress had not specifically regulated an issuerelating to interstate commerce, the states could do so, as long as their regulations did not give their own states' businesses an unfair advantage overout-of-state firms. The Court also found that a state could pass laws affecting interstate commerce, if local safety concerns outweighed any burden on that commerce.
Giving Congress the ability to regulate commerce was a top priority for the framers of the Constitution. Under the old Articles of Confederacy, the statesoperated almost as mini-nations, imposing tariffs on each other and issuingtheir own money. "Most of our political evils," wrote James Madison, "may betraced to our commercial ones." Article I, section 8 of the Constitution gives Congress the power to regulate interstate commerce, and the legislature hasused the Commerce Clause broadly to achieve national goals. But that power is not absolute; the Supreme Court has found instances in which the states canstill pass laws affecting interstate commerce, as in South Carolina StateHighway Department v. Barnwell Bros., Inc.
In 1933, South Carolina passed a law that limited the width of trucks on itshighways to 90 inches. The weight of the loads carried was also restricted, to no more than 20,000 pounds. Various truckers and shippers, including Barnwell Bros., Inc., brought suit to prevent the state from enforcing the law. Therestrictions were much tougher than the ones in neighboring states and wouldhave affected up to 90 percent of the trucks that passed through South Carolina. The district court found that the restrictions were unreasonable and a burden on interstate commerce. The court ordered South Carolina not to enforcethe law.
The defendants in that trial, which included the state of South Carolina andsome railway companies, then appealed to the Supreme Court. The Court, with three members absent, voted unanimously to reverse the lower court and upholdthe South Carolina regulations.
Intrastate and Interstate Interests Treated the Same
Writing for the Court, Justice Stone noted that "few subjects of state regulation are so peculiarly of local concern as is the issue of state highways . .. The state has a primary and immediate concern in their safe and economicaladministration." Despite that, South Carolina's restrictions may have been unconstitutional if they had contradicted congressional guidelines on the weight and width of trucks. However, the Motor Carrier Act, passed by Congress in1935, did not set national standards for trucks, so the states were free toset their own. In addition, the state established those guidelines to ensuresafety on the highways, and in this case that safety issue outweighed any burden on interstate commerce.
Another key point was whether the South Carolina regulations discriminated against interstate businesses, thereby giving state firms an unfair competitiveadvantage. All trucks, however, were subject to the restrictions. Stone commented, "The fact that [the regulations] affect alike shippers in interstate and intrastate commerce in large number within as well as without the state isa safeguard against their abuse."
Underlying that sentiment was the assumption that if the regulations were grossly unfair, South Carolina truckers could use their political influence in the state legislature to have the laws changed. The Court, however, should notbe involved in determining if the details of the statute were reasonable, once it had established that the state did have the right to pass them. Stone wrote:
After losing their case in the Supreme Court, the appellees and other South Carolina truckers did just as Stone implied: they went to the state legislature. Three months after the Supreme Court decision, the South Carolina legislature expanded its width and weight regulations for trucks.
Future Restrictions on the States
After South Carolina State Highway Department, the Supreme Court was not always so sympathetic to the states regarding the Commerce Clause. In general, the Court gave the states less leeway in regulating railways versus highways. In Southern Pacific Co. v. Arizona (1945) the Court struck downa state law limiting the number of cars on trains traveling through Arizona.In that case, the Court said the safety issue involved did not outweigh the burden on interstate commerce.
Gradually, the Court also limited the states' power over regulating highways.It struck down an Illinois law that required a specific type of mud flap fortrucks using state highways. In Bibb v. Navajo Freight Lines (1959),the Court said the state law was not discriminatory, but its safety intent did place an unreasonable burden on interstate commerce. Later decisions struckdown state laws prohibiting double-trailer trucks and other oversized truckson state highways.
Related Cases
Big Rig Road Hazards
Sources
National Highway Traffic Safety Administration.
South Carolina State Highway Department, et al.
Appellees
Barnwell Bros., Inc. et al.
Appellants' Claim
That South Carolina restrictions on the weight and width of trucks did not violate the Commerce Clause of the Constitution.
Chief Lawyers for Appellants
Steve C. Griffith, Thomas W. Davis, and Eugene S. Blease
Chief Lawyers for Appellees
S. King Funkhouser and Frank Coleman
Justices for the Court
Hugo Lafayette Black, Louis D. Brandeis, Pierce Butler, Charles Evans Hughes,James Clark McReynolds, Owen Josephus Roberts, Harlan Fiske Stone (writing for the Court)
Justices Dissenting
None (Benjamin N. Cardozo and Stanley Forman Reed did not participate)
Place
Washington, D.C.
Date of Decision
14 February 1938
Decision
Found for the appellants, reversing the lower court's order to enjoin enforcement of the state regulations.
Significance
The Court reaffirmed that if Congress had not specifically regulated an issuerelating to interstate commerce, the states could do so, as long as their regulations did not give their own states' businesses an unfair advantage overout-of-state firms. The Court also found that a state could pass laws affecting interstate commerce, if local safety concerns outweighed any burden on that commerce.
Giving Congress the ability to regulate commerce was a top priority for the framers of the Constitution. Under the old Articles of Confederacy, the statesoperated almost as mini-nations, imposing tariffs on each other and issuingtheir own money. "Most of our political evils," wrote James Madison, "may betraced to our commercial ones." Article I, section 8 of the Constitution gives Congress the power to regulate interstate commerce, and the legislature hasused the Commerce Clause broadly to achieve national goals. But that power is not absolute; the Supreme Court has found instances in which the states canstill pass laws affecting interstate commerce, as in South Carolina StateHighway Department v. Barnwell Bros., Inc.
In 1933, South Carolina passed a law that limited the width of trucks on itshighways to 90 inches. The weight of the loads carried was also restricted, to no more than 20,000 pounds. Various truckers and shippers, including Barnwell Bros., Inc., brought suit to prevent the state from enforcing the law. Therestrictions were much tougher than the ones in neighboring states and wouldhave affected up to 90 percent of the trucks that passed through South Carolina. The district court found that the restrictions were unreasonable and a burden on interstate commerce. The court ordered South Carolina not to enforcethe law.
The defendants in that trial, which included the state of South Carolina andsome railway companies, then appealed to the Supreme Court. The Court, with three members absent, voted unanimously to reverse the lower court and upholdthe South Carolina regulations.
Intrastate and Interstate Interests Treated the Same
Writing for the Court, Justice Stone noted that "few subjects of state regulation are so peculiarly of local concern as is the issue of state highways . .. The state has a primary and immediate concern in their safe and economicaladministration." Despite that, South Carolina's restrictions may have been unconstitutional if they had contradicted congressional guidelines on the weight and width of trucks. However, the Motor Carrier Act, passed by Congress in1935, did not set national standards for trucks, so the states were free toset their own. In addition, the state established those guidelines to ensuresafety on the highways, and in this case that safety issue outweighed any burden on interstate commerce.
Another key point was whether the South Carolina regulations discriminated against interstate businesses, thereby giving state firms an unfair competitiveadvantage. All trucks, however, were subject to the restrictions. Stone commented, "The fact that [the regulations] affect alike shippers in interstate and intrastate commerce in large number within as well as without the state isa safeguard against their abuse."
Underlying that sentiment was the assumption that if the regulations were grossly unfair, South Carolina truckers could use their political influence in the state legislature to have the laws changed. The Court, however, should notbe involved in determining if the details of the statute were reasonable, once it had established that the state did have the right to pass them. Stone wrote:
When the action of a Legislature is within the scope of itspower, fairly debatable questions as to its reasonableness, wisdom, and propriety are not for the determination of courts, but for the legislative body .. . It is not any the less a legislative power committed to the states because it affects interstate commerce, and courts are not any more entitled, because interstate commerce is affected, to substitute their own for the legislative judgment.
After losing their case in the Supreme Court, the appellees and other South Carolina truckers did just as Stone implied: they went to the state legislature. Three months after the Supreme Court decision, the South Carolina legislature expanded its width and weight regulations for trucks.
Future Restrictions on the States
After South Carolina State Highway Department, the Supreme Court was not always so sympathetic to the states regarding the Commerce Clause. In general, the Court gave the states less leeway in regulating railways versus highways. In Southern Pacific Co. v. Arizona (1945) the Court struck downa state law limiting the number of cars on trains traveling through Arizona.In that case, the Court said the safety issue involved did not outweigh the burden on interstate commerce.
Gradually, the Court also limited the states' power over regulating highways.It struck down an Illinois law that required a specific type of mud flap fortrucks using state highways. In Bibb v. Navajo Freight Lines (1959),the Court said the state law was not discriminatory, but its safety intent did place an unreasonable burden on interstate commerce. Later decisions struckdown state laws prohibiting double-trailer trucks and other oversized truckson state highways.
Related Cases
- Village of Euclid v. Ambler Realty Co., 272 U.S. 365 (1926).
- Baldwin v. G. A. F. Seelig, Inc., 294 U.S. 511 (1935).
- Southern Pacific Co. v. Arizona, 325 U.S. 761 (1945).
- Bibb v. Navajo Freight Lines, 359 U.S. 520 (1959).
Big Rig Road Hazards
- Fatigue and lack of sleep are the number one causes of collisions involving big trucks.
- A National Transportation Safety Board survey found that fatigue was a factor in 30 to 40 percent of truck accidents.
- In more than 30 percent of crashes in which a truck driver died, fatigue was the most likely cause.
- In one survey, at least 19 percent of truck drivers admitted to falling asleep at the wheel within the past month.
- Asurvey of long-haul truckers driving from Washington to Minnesota demonstrated that nearly 60 percent of those trucks drove longer than they were supposed to.
- Logging false hours is so common that many drivers call them "comic books" or "joke books."
- Truckers attribute their willingness tobreak hours of service rules to financial pressures.
- One out of eighttraffic fatalities in 1997 resulted from an accident involving a big rig.
- 98 percent of the people killed in two-vehicle accidents involving a passenger vehicle and a large truck in 1997 were occupants of the passenger vehicle.
- In 1997, 717 large truck occupants died, a 16 percent increaseover 1996.
Sources
National Highway Traffic Safety Administration.
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