Southern Pacific Co. v. Arizona

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. Only when local laws were in conflict with some national policy could congressional legislation supersede the local statute. Even if this were the case in the Southern 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 railway lines 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 resulted in the railroads having to assemble hundreds more trains annually, which slowed the pace of transportation well beyond the state's borders. By obstructing the I.C.C.'s mandate to promote adequate, economical, and efficient national transportation 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 local discrimination 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 railway workers in the name of economic expediency. By his logic, this was not even a decision the Court should make. Justice Black felt that the train limit case was a public policy issue which should be settled by elected officials, not by 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."