Tuesday, November 5, 2013

Houston, East & West Texas Railway Co. v. United States (The Shreveport Rate Cases) case brief

Houston, East & West Texas Railway Co. v. United States (The Shreveport Rate Cases) case brief summary
234 U.S. 342 (1914)

Appellant railroads sought review of an order from the United States Commerce Court, which upheld appellee Interstate Commerce Commission's order. The order required the railroads to cease discriminatory rates among interstate and intrastate travel.

A complaint was filed against the railroads, alleging that the railroads were discriminating against interstate commerce by charging higher rates for interstate travel than for intrastate travel. The commission ordered the railroads to cease the discriminatory practice, and the commerce court upheld the commission's order.

  • On appeal, the court upheld the commerce court's order, rejecting the railroads' claims that because they engaged in intrastate as well as interstate commerce, congress lacked the power to regulate its rates. 
  • The court further held that congress had delegated the commission to act on its behalf in ensuring that the railroads' rate did not discriminate against interstate commerce. 
  • The court also rejected the railroads' claims that because their rate practices were caused by conditions wholly beyond their control, congress lacked the authority to regulate the practices.

The court affirmed the commerce court's judgment, which upheld the commission's order.

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