Appellant
Southern Pacific Company
Appellee
State of Arizona
Appellant's Claim
That the Arizona Supreme Court erred in its ruling that the state's Train Limit Law was constitutional.
Chief Lawyer for Appellant
Burton Mason
Chief Lawyer for Appellee
Harold N. McLaughlin
Justices for the Court
Felix Frankfurter, Robert H. Jackson, Frank Murphy, Stanley Forman Reed, OwenJosephus Roberts, Wiley Blount Rutledge, Harlan Fiske Stone (writing for theCourt)
Justices Dissenting
Hugo Lafayette Black, William O. Douglas
Place
Washington, D.C.
Date of Decision
18 June 1945
Decision
In favor of appellant, invalidating the Train Limit Law.
Significance
The Court ruled that state regulations which burden interstate commerce are unconstitutional.
The Arizona Train Limit Law
By the time the Southern Pacific Company and the state of Arizona squared offbefore the U.S. Supreme Court, the two sides had been battling before courtsfor 15 years. The germ of the controversy lay within a 1912 Arizona law prohibiting operation of railroad trains of more than 14 passenger cars or 70 freight cars within the state. At the time it was passed, the law was uncontroversial because it reflected a relatively standard train length. As track systems were modernized and stronger locomotives appeared, the Arizona limit became a nuisance to the Southern Pacific Company. The railroad found that it hadto stop and shorten its freight trains at terminals near the New Mexico and California borders in order to pass through Arizona without being heavily fined. It was only a matter of time before the issue landed in court.
In 1939, after ten years of unsuccessful preliminary legal skirmishes, the Southern Pacific Company filed suit against Arizona Attorney General Joe Conway, asking a federal court to declare that the Train Limit Law was unconstitutional. In an unusual legal maneuver, Conway ignored the suit. The court dismissed the case, since no controversy appeared to exist for it to adjudicate. When Southern Pacific began to run long trains through the state, however, therailroad forced Conway's hand. He filed suit against Southern Pacific in April of 1940 for violating the Train Limit Law. In its defense, the railroad responded by attacking the constitutionality of the law.
After months of exhaustive hearings, the railroad convinced the Pima County Court that longer trains were safer and less financially burdensome than thoseoperating under the limit law. Conway quickly appealed the case to the Arizona Supreme Court. This time, the state law was interpreted to be valid. On 23December 1943, the Arizona Supreme Court reversed the county court's judgment and found the railroad liable for fines due to violation of the Train LimitLaw.
Appeal to the U.S. Supreme Court
The railroad appealed the Arizona court's decision before the U.S. Supreme Court on 27 and 28 March 1945. The state of Arizona continued to insist that the limit law was a public safety regulation. While the "commerce clause" of section 8 of the U.S. Constitution gives Congress the power to regulate commerce between the states, neither Congress nor the Interstate Commerce Commission(I.C.C.) had the right to pass laws over-riding local safety statutes. Onlywhen local laws were in conflict with some national policy could congressional legislation supersede the local statute. Even if this were the case in theSouthern Pacific dispute, attorneys for the state of Arizona argued, such a conflict should be debated and corrected by Congress, not by the Court.
The U.S. Supreme Court justices agreed that federal regulation alone should not displace local laws based upon safety considerations. In the Court's decision of 18 June 1945, however, the majority found the railroad's safety statistics more compelling than those offered by Arizona. In the written opinion, Chief Justice Stone noted that the accident rate on Arizona's limited railwaylines was higher, not lower, than in other states with comparable rail systems.
Yet the Court's decision centered on the effect of the limit law on interstate commerce. Shortening the length of trains passing through Arizona resultedin the railroads having to assemble hundreds more trains annually, which slowed the pace of transportation well beyond the state's borders. By obstructingthe I.C.C.'s mandate to promote adequate, economical, and efficient nationaltransportation service, the limit law placed an unacceptable burden on interstate commerce. The Arizona Supreme Court's decision was reversed.
Justices Black and Douglas dissented in separate opinions. Both agreed that federal regulations should only intrude on state transportation laws if localdiscrimination against interstate commerce existed. Neither judge was convinced that this was the case in the Southern Pacific suit, nor did they accept that longer trains were safer. Both agreed that the Arizona law should be allowed to stand as a safety measure.
Justice Black accused the majority of making life more dangerous for railwayworkers in the name of economic expediency. By his logic, this was not even adecision the Court should make. Justice Black felt that the train limit casewas a public policy issue which should be settled by elected officials, notby a court.
Despite the dissents, the Court asserted its right to settle the dispute between Arizona and the Southern Pacific Company. "The commerce clause," wrote Justice Stone, "even without the aid of congressional legislation, protects against state legislation which is inimicable to the national commerce, and in such cases, where Congress has not acted, this Court, and not the state legislature, is the final arbiter of the competing demands of state and national interests."
Related Cases
The Commerce Clause
Congress is authorized, under Article 1, Section 8, Clause 3, of the Constitution, "to regulate Commerce with foreign Nations, and among several States, and with the Indian Tribes." This is the Commerce Clause, the basis for a number of Supreme Court challenges involving alleged attempts by individuals, companies, or--in the case of Southern Pacific Co. v. Arizona--states toimpede the flow of interstate commerce.
"Commerce," as defined by the Constitution, has a very broad meaning. The term encompasses any sort of business or commercial exchange and all interstatecommunication via telephone, telegraph, radio, or other electronic means. Inaddition, it refers to all interstate travel, whether for business or for personal reasons.
States have control over their intrastate commerce, but interstate commerce is completely under federal control. This provision was designed to prevent competition between states with seaports and those without and to help to preserve the doctrine of federalism in the operation of the country's internal affairs.
Sources
West's Encyclopedia of American Law. St. Paul, MN: West Group, 1998.
Southern Pacific Company
Appellee
State of Arizona
Appellant's Claim
That the Arizona Supreme Court erred in its ruling that the state's Train Limit Law was constitutional.
Chief Lawyer for Appellant
Burton Mason
Chief Lawyer for Appellee
Harold N. McLaughlin
Justices for the Court
Felix Frankfurter, Robert H. Jackson, Frank Murphy, Stanley Forman Reed, OwenJosephus Roberts, Wiley Blount Rutledge, Harlan Fiske Stone (writing for theCourt)
Justices Dissenting
Hugo Lafayette Black, William O. Douglas
Place
Washington, D.C.
Date of Decision
18 June 1945
Decision
In favor of appellant, invalidating the Train Limit Law.
Significance
The Court ruled that state regulations which burden interstate commerce are unconstitutional.
The Arizona Train Limit Law
By the time the Southern Pacific Company and the state of Arizona squared offbefore the U.S. Supreme Court, the two sides had been battling before courtsfor 15 years. The germ of the controversy lay within a 1912 Arizona law prohibiting operation of railroad trains of more than 14 passenger cars or 70 freight cars within the state. At the time it was passed, the law was uncontroversial because it reflected a relatively standard train length. As track systems were modernized and stronger locomotives appeared, the Arizona limit became a nuisance to the Southern Pacific Company. The railroad found that it hadto stop and shorten its freight trains at terminals near the New Mexico and California borders in order to pass through Arizona without being heavily fined. It was only a matter of time before the issue landed in court.
In 1939, after ten years of unsuccessful preliminary legal skirmishes, the Southern Pacific Company filed suit against Arizona Attorney General Joe Conway, asking a federal court to declare that the Train Limit Law was unconstitutional. In an unusual legal maneuver, Conway ignored the suit. The court dismissed the case, since no controversy appeared to exist for it to adjudicate. When Southern Pacific began to run long trains through the state, however, therailroad forced Conway's hand. He filed suit against Southern Pacific in April of 1940 for violating the Train Limit Law. In its defense, the railroad responded by attacking the constitutionality of the law.
After months of exhaustive hearings, the railroad convinced the Pima County Court that longer trains were safer and less financially burdensome than thoseoperating under the limit law. Conway quickly appealed the case to the Arizona Supreme Court. This time, the state law was interpreted to be valid. On 23December 1943, the Arizona Supreme Court reversed the county court's judgment and found the railroad liable for fines due to violation of the Train LimitLaw.
Appeal to the U.S. Supreme Court
The railroad appealed the Arizona court's decision before the U.S. Supreme Court on 27 and 28 March 1945. The state of Arizona continued to insist that the limit law was a public safety regulation. While the "commerce clause" of section 8 of the U.S. Constitution gives Congress the power to regulate commerce between the states, neither Congress nor the Interstate Commerce Commission(I.C.C.) had the right to pass laws over-riding local safety statutes. Onlywhen local laws were in conflict with some national policy could congressional legislation supersede the local statute. Even if this were the case in theSouthern Pacific dispute, attorneys for the state of Arizona argued, such a conflict should be debated and corrected by Congress, not by the Court.
The U.S. Supreme Court justices agreed that federal regulation alone should not displace local laws based upon safety considerations. In the Court's decision of 18 June 1945, however, the majority found the railroad's safety statistics more compelling than those offered by Arizona. In the written opinion, Chief Justice Stone noted that the accident rate on Arizona's limited railwaylines was higher, not lower, than in other states with comparable rail systems.
Yet the Court's decision centered on the effect of the limit law on interstate commerce. Shortening the length of trains passing through Arizona resultedin the railroads having to assemble hundreds more trains annually, which slowed the pace of transportation well beyond the state's borders. By obstructingthe I.C.C.'s mandate to promote adequate, economical, and efficient nationaltransportation service, the limit law placed an unacceptable burden on interstate commerce. The Arizona Supreme Court's decision was reversed.
Justices Black and Douglas dissented in separate opinions. Both agreed that federal regulations should only intrude on state transportation laws if localdiscrimination against interstate commerce existed. Neither judge was convinced that this was the case in the Southern Pacific suit, nor did they accept that longer trains were safer. Both agreed that the Arizona law should be allowed to stand as a safety measure.
Justice Black accused the majority of making life more dangerous for railwayworkers in the name of economic expediency. By his logic, this was not even adecision the Court should make. Justice Black felt that the train limit casewas a public policy issue which should be settled by elected officials, notby a court.
Despite the dissents, the Court asserted its right to settle the dispute between Arizona and the Southern Pacific Company. "The commerce clause," wrote Justice Stone, "even without the aid of congressional legislation, protects against state legislation which is inimicable to the national commerce, and in such cases, where Congress has not acted, this Court, and not the state legislature, is the final arbiter of the competing demands of state and national interests."
Related Cases
- Leisy v. Hardin, 135 U.S. 100 (1890).
- Baldwin v. G. A. F. Seelig, Inc., 294 U.S. 511 (1935).
- South Carolina State Highway Dept. v. Barnwell Brothers, Inc., 303U.S. 177 (1938).
The Commerce Clause
Congress is authorized, under Article 1, Section 8, Clause 3, of the Constitution, "to regulate Commerce with foreign Nations, and among several States, and with the Indian Tribes." This is the Commerce Clause, the basis for a number of Supreme Court challenges involving alleged attempts by individuals, companies, or--in the case of Southern Pacific Co. v. Arizona--states toimpede the flow of interstate commerce.
"Commerce," as defined by the Constitution, has a very broad meaning. The term encompasses any sort of business or commercial exchange and all interstatecommunication via telephone, telegraph, radio, or other electronic means. Inaddition, it refers to all interstate travel, whether for business or for personal reasons.
States have control over their intrastate commerce, but interstate commerce is completely under federal control. This provision was designed to prevent competition between states with seaports and those without and to help to preserve the doctrine of federalism in the operation of the country's internal affairs.
Sources
West's Encyclopedia of American Law. St. Paul, MN: West Group, 1998.
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