Tuesday, March 26, 2013

Minneapolis & St. Louis Railway Co. v. Columbus Rolling– Mill Co. case brief

Minneapolis & St. Louis Railway Co. v. Columbus Rolling– Mill Co. case brief summary
7 S. Ct. 168

SYNOPSIS:
Defendant railway company filed a writ of error to the Supreme Court of the State of Illinois, which affirmed a judgment rendered against the railway in plaintiff State of Illinois' suit charging that the railway had, in violation of a state statute, been guilty of an unjust discrimination in its rates or charges of toll and compensation for the transportation of freight.

OVERVIEW: The State of Illinois alleged that the railroad company charged a shipper a rate of 15 cents per 100 pounds for a car-load, while charging another shipper at a rate of 25 cents per 100 pounds. The freight was in the same class in both instances, and carried over the same road, except as to the difference in the distance. The statute that was supposed to be violated by the transaction was Ill. Rev. Stat. ch. 114, § 126.

HOLDING:
The Court concluded that the type of regulation was one that had to be, if established at all, of a general and national character, and could not be safely and wisely remitted to local rules and local regulations.
-The statute was a regulation of commerce, and of a national scope.

ANALYSIS:
-Accordingly, the regulation could only appropriately exist if it had been enacted by the Congress of the United States under the Commerce Clause of the Constitution.
-Because it was not, it was void and unenforceable.

OUTCOME: The Court reversed the judgment and the case was remanded to the Supreme Court of Illinois for further proceedings in conformity with the opinion.

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