New York Cent. & H.R.R. v. United States case brief

 

New York Cent. & H.R.R. v. U.S.: Railroad and its assistant traffic manager were convicted for the payment of rebates to the American Sugar Refining Company. The argument of the company is that to punish the corporation is in reality to punish the innocent stockholders, and to deprive them of their property without due process.

• At common law, Blackstone wrote: “A corporation cannot commit treason, felony, or other crime in its corporate capacity, though its members may in their distinct individual capacities.”
• The modern authority, Bishop’s New Criminal Law § 417: since a corporation acts by its officers and agents their purposes, motives, and intent are just as much those of the corporation as are the things done.
• It is now well established that in actions for tort the corporation may be held responsible for damages for the acts of its agents within the scope of his employment.
  • We see no good reason why corporations may not be held responsible for and charged with the knowledge and purposes of their agents, acting within the authority conferred upon them.
• We see no valid objection in law, and every reason in public policy, why the corporation, which profits by the transaction, and can only act through its agents and officers.