Appellant
State of Illinois
Appellee
Navajo Freight Lines and other interstate trucking companies
Appellant's Claim
Illinois should be allowed to require contoured mudguards on the rear fendersof trucks and trailers.
Chief Lawyer for Appellant
Latham Castle
Chief Lawyer for Appellee
David Axelrod
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., Tom C. Clark, William O. Douglas (writing for the Court), Felix Frankfurter, John Marshall Harlan II, Potter Stewart, Earl Warren, Charles Evans Whittaker
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
25 May 1959
Decision
lllinois may not require contoured rear mudguards.
Significance
The Court normally upheld state safety regulations. However, the safety advantages of contoured mudguards were too inconclusive to justify the "great burden" they imposed on interstate motor carriers. Hence the Illinois law was unconstitutional under the "commerce clause."
Under an Illinois law effective 8 July 1957, all trucks and trailers operating in that state had to be equipped with contoured rear-fender mudguards. Navajo Freight Lines and other interstate trucking companies challenged the law'sconstitutionality. When it was overturned by the district court, Illinois appealed to the Supreme Court. (Bibb lent his name to the case as state director of public safety.)
When May a State Regulate Interstate Commerce?
Article I, section 8 of the Constitution grants Congress power "to regulate Commerce with foreign Nations, and among the several states, and with the Indian Tribes." However, the Constitution is silent as to whether the states (inaddition to Congress) may or may not pass laws that affect interstate commerce.
The Supreme Court has recognized a state "police power" to regulate businessand industry in order to protect public health and safety. Often state regulations significantly affect the movement of goods and service between the states. Nevertheless, the Court has upheld state laws that pass three tests. First, a state law can not conflict with a valid federal law. Second, the regulation has to be rationally related to a legitimate state end. Finally, the burdens (financial and otherwise) the regulation imposes have to be outweighed bythe state's interest in enforcing the regulation.
When Bibb reached the Supreme Court, the justices unanimously affirmedthe district court decision, with Justice Douglas delivering the Court's opinion. Justice Douglas began by affirming the principle that state "safety measures carry a strong presumption of validity." Citing Southern Pacific Co.v. Arizona (1945), Douglas declared that the Court overruled state safety laws only when their benefits in reducing accidents and causalities were "slight or problematical." In these cases, the small benefits do not "outweighthe national interest in keeping interstate commerce free from interferenceswhich seriously impede it."
Illinois' Peculiar Mudguards
By requiring unusual mudguards, the Illinois law placed a heavy burden on interstate commerce. Only Illinois mandated contoured mudguards. Straight mudguards were required in Arkansas and permitted in at least 45 other states.
Substantial and repeated costs would be incurred to install, maintain, and replace the contoured mudguards. Since the two states required different typesof mudguards, the cost would be especially high for vehicles operating in both Illinois and Arkansas. These trailers would have to stop to change mudguards every time they crossed the state border.
In addition, the law would seriously interfere with the trucking companies' "interline operations." Using this procedure, two carriers interchanged entiretrailers rather than unloading and reloading the cargo. Interlining was particularly important in shipping perishable goods and explosives carried underseal. A firm not operating in Illinois would not equip its trailers with contoured mudguards. Thus its trailers could not be used by Illinois companies under the "interlining" procedure.
Small Benefits Do Not Justify Great Costs
The attorneys for Illinois did not attempt to rebut claims that the law burdened interstate commerce. Instead they argued that contoured mudguards increased safety. Specifically contoured mudguards "prevented the throwing of debrisinto the faces of drivers of passing cars and into the windshields of a following vehicle." However, Justice Douglas noted, these safety advantages had not been proved. Moreover, contoured mudguards created new safety hazards notfound when straight mudguards were used.
Justice Douglas concluded that this was one of the rare cases where a state safety measure was unconstitutional even though it did not discriminate against persons from other states.
Related Cases
Interstate Commerce Act of 1887
At one point railroads were regulated by states, but those efforts were unsuccessful because the laws were too rigid. Then the Granger Laws were implemented, which arose out of specific complaints that farmers had against the railroads. Farmers believed that the rates charged to transport their goods by therailroads were too high. Yet, the Grangers Laws were also unsuccessful because they lacked uniformity.
Then in 1886, the Supreme Court ruled in Wabash, St. Louis & Pacific Ry. Co. v. Illinois that the Commerce Clause of the Constitution allowed only for federal regulation of interstate commerce, which resulted in the Interstate Commerce Act of 1887.
The Interstate Commerce Act outlawed unfair discrimination against shippers with the use of rebates, pools, drawbacks and long-short haul discrepancies. It required that railroad rates be reasonable and published and could not be changed without adequate public notices. Later, the Interstate Commerce Commission was created to enforce compliance.
Sources
West's Encyclopedia of American Law.Volume 1. Minneapolis, MN: West Publishing, 1998.
State of Illinois
Appellee
Navajo Freight Lines and other interstate trucking companies
Appellant's Claim
Illinois should be allowed to require contoured mudguards on the rear fendersof trucks and trailers.
Chief Lawyer for Appellant
Latham Castle
Chief Lawyer for Appellee
David Axelrod
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., Tom C. Clark, William O. Douglas (writing for the Court), Felix Frankfurter, John Marshall Harlan II, Potter Stewart, Earl Warren, Charles Evans Whittaker
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
25 May 1959
Decision
lllinois may not require contoured rear mudguards.
Significance
The Court normally upheld state safety regulations. However, the safety advantages of contoured mudguards were too inconclusive to justify the "great burden" they imposed on interstate motor carriers. Hence the Illinois law was unconstitutional under the "commerce clause."
Under an Illinois law effective 8 July 1957, all trucks and trailers operating in that state had to be equipped with contoured rear-fender mudguards. Navajo Freight Lines and other interstate trucking companies challenged the law'sconstitutionality. When it was overturned by the district court, Illinois appealed to the Supreme Court. (Bibb lent his name to the case as state director of public safety.)
When May a State Regulate Interstate Commerce?
Article I, section 8 of the Constitution grants Congress power "to regulate Commerce with foreign Nations, and among the several states, and with the Indian Tribes." However, the Constitution is silent as to whether the states (inaddition to Congress) may or may not pass laws that affect interstate commerce.
The Supreme Court has recognized a state "police power" to regulate businessand industry in order to protect public health and safety. Often state regulations significantly affect the movement of goods and service between the states. Nevertheless, the Court has upheld state laws that pass three tests. First, a state law can not conflict with a valid federal law. Second, the regulation has to be rationally related to a legitimate state end. Finally, the burdens (financial and otherwise) the regulation imposes have to be outweighed bythe state's interest in enforcing the regulation.
When Bibb reached the Supreme Court, the justices unanimously affirmedthe district court decision, with Justice Douglas delivering the Court's opinion. Justice Douglas began by affirming the principle that state "safety measures carry a strong presumption of validity." Citing Southern Pacific Co.v. Arizona (1945), Douglas declared that the Court overruled state safety laws only when their benefits in reducing accidents and causalities were "slight or problematical." In these cases, the small benefits do not "outweighthe national interest in keeping interstate commerce free from interferenceswhich seriously impede it."
Illinois' Peculiar Mudguards
By requiring unusual mudguards, the Illinois law placed a heavy burden on interstate commerce. Only Illinois mandated contoured mudguards. Straight mudguards were required in Arkansas and permitted in at least 45 other states.
Substantial and repeated costs would be incurred to install, maintain, and replace the contoured mudguards. Since the two states required different typesof mudguards, the cost would be especially high for vehicles operating in both Illinois and Arkansas. These trailers would have to stop to change mudguards every time they crossed the state border.
In addition, the law would seriously interfere with the trucking companies' "interline operations." Using this procedure, two carriers interchanged entiretrailers rather than unloading and reloading the cargo. Interlining was particularly important in shipping perishable goods and explosives carried underseal. A firm not operating in Illinois would not equip its trailers with contoured mudguards. Thus its trailers could not be used by Illinois companies under the "interlining" procedure.
Small Benefits Do Not Justify Great Costs
The attorneys for Illinois did not attempt to rebut claims that the law burdened interstate commerce. Instead they argued that contoured mudguards increased safety. Specifically contoured mudguards "prevented the throwing of debrisinto the faces of drivers of passing cars and into the windshields of a following vehicle." However, Justice Douglas noted, these safety advantages had not been proved. Moreover, contoured mudguards created new safety hazards notfound when straight mudguards were used.
Justice Douglas concluded that this was one of the rare cases where a state safety measure was unconstitutional even though it did not discriminate against persons from other states.
We deal not with absolutes but withquestions of degree. The state legislatures plainly have great leeway in providing safety regulations for all vehicles--interstate as well as local . . .Yet the heavy burden which the Illinois mudguard law places on the interstatemovement of trucks and trailers . . . [goes beyond] the permissible limits even for safety regulations.
Related Cases
- Southern Pacific Co. v. Arizona, 325 U.S. 761 (1945).
- Raymond Motor Transp., Inc. v. Rice, 417 F.Supp. 1352 (1976).
Interstate Commerce Act of 1887
At one point railroads were regulated by states, but those efforts were unsuccessful because the laws were too rigid. Then the Granger Laws were implemented, which arose out of specific complaints that farmers had against the railroads. Farmers believed that the rates charged to transport their goods by therailroads were too high. Yet, the Grangers Laws were also unsuccessful because they lacked uniformity.
Then in 1886, the Supreme Court ruled in Wabash, St. Louis & Pacific Ry. Co. v. Illinois that the Commerce Clause of the Constitution allowed only for federal regulation of interstate commerce, which resulted in the Interstate Commerce Act of 1887.
The Interstate Commerce Act outlawed unfair discrimination against shippers with the use of rebates, pools, drawbacks and long-short haul discrepancies. It required that railroad rates be reasonable and published and could not be changed without adequate public notices. Later, the Interstate Commerce Commission was created to enforce compliance.
Sources
West's Encyclopedia of American Law.Volume 1. Minneapolis, MN: West Publishing, 1998.
Further Readings
- Biskupic, Joan, and Elder Witt, eds. Congressional Quarterly's Guide to the U.S. Supreme Court, 3rd ed. Washington, DC: Congressional Quarterly, Inc., 1996.
- Gavit, Bernard. The Commerce Clause of the United States Constitution. New York: AMS Press, 1970.
- Tribe, Laurence. American Constitutional Law, 2nd ed. Mineola, NY:Foundation, 1978.
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