Bibb v. Navajo Freight Lines

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 the railroads 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.