Friday, November 15, 2013

Southern Pacific Co. v. Arizona Ex Rel. Sullivan, Attorney General case brief

Southern Pacific Co. v. Arizona Ex Rel. Sullivan, Attorney General case brief summary
325 U.S. 761 (1945)

Appellant railroad challenged a judgment of the Supreme Court of Arizona in favor of appellee state upholding the constitutionality of the Arizona Train Limit Law of May 16, 1912, Ariz. Rev. Stat. Ann. § 69-119 (1939).

The state brought an action against railroad company to recover statutory penalties for operating within the state two interstate trains, one a passenger train of more than 14 cars and one a freight train of more than 70 cars. The trial court gave judgment for the railroad company. The Supreme Court of Arizona reversed and directed judgment for the state.

On appeal, railroad's principal contention was that § 69-119 contravened the Commerce Clause of the Federal Constitution.

The Court held that although the commerce clause conferred on the national government power to regulate commerce, its possession of the power did not exclude all state power of regulation.


  • However, the Court found that the states were not deemed to have authority to impede substantially the free flow of commerce from state to state, or to regulate those phases of the national commerce which, because of the need of national uniformity, demanded that their regulation be prescribed by a single authority. 
  • The court concluded that § 69-119 went too far, having a seriously adverse effect on transportation efficiency and economy, and passed beyond what was plainly essential for safety.


The judgment was reversed.

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