United States v. Florida East Coast Railway Co. case brief

United States v. Florida East Coast Railway Co. case brief summary
410 U.S. 224 (1973)

CASE SYNOPSIS

Appellee railroad companies brought an action in the District Court for the Middle District of Florida to set aside the incentive per diem rates established by appellant Interstate Commerce Commission (Commission) in a rulemaking proceeding. The district court sustained railroads' position that the Commission had failed to comply with the applicable provisions of the Administrative Procedure Act, 5 U.S.C.S. § 551 et seq.

CASE FACTS
The district court held that the language of 49 U.S.C.S. § 1(14)(a) of the Interstate Commerce Act required the Commission in a proceeding to act in accordance with the Administrative Procedure Act, 5 U.S.C.S. § 556(d). Thus, the district court held that the Commission's determination to receive submissions from railroads only in written form was a violation of § 556(d) because railroads were prejudiced by that determination.

DISCUSSION

• On appeal, the court held that inextricably intertwined with the hearing requirement of the Administrative Procedure Act in this case was the meaning to be given to the language "after hearing" in 49 U.S.C.S. § 1(14)(a). 
• The court held that the term "hearing" as used § 1(14)(a) did not necessarily embrace either the right to present evidence orally and to cross-examine opposing witnesses, or the right to present oral argument to the agency's decisionmaker. 
• Thus, the court concluded that the hearing requirement of § 1(14)(a) was met.

OUTCOME

The judgment was reversed and the matter was remanded so that the district court could consider those contentions of the parties that were not disposed of by this opinion.

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