Friday, November 1, 2013

United States v. Ludlum Steel Corp. case brief

United States v. Ludlum Steel Corp. case brief summary
406 U.S. 742 (1972)

The United States sought review of a judgment by the United States District Court for the Western District of Pennsylvania, which invalidated an order by the Interstate Commerce Commission that promulgated two car-service rules. Respondents, railroads and shippers, initiated the suit to enjoin enforcement of the rules.

The Commission's car-service rules had the general effect of requiring that freight cars, after being unloaded, be returned in the direction of the lines of the road owning the cars. The Commission promulgated these rules in response to its finding that there was a national shortage of freight car ownership. The district court invalidated the rules, holding that the were not reasonable under the Esch Car Service Act, 49 U.S.C.S. § 1(14)(a).

  • Upholding the Commission's authority to issue the car-service rules, the Court stated that the Commission's finding of an inadequate freight car supply to service shippers was supported by substantial evidence. 
  • The Court held that there was sufficient relationship between the Commission's conclusions and the factual bases in the record upon which it relied to substantively support this exercise of its authority under the Esch Act. 
  • The Court concluded that the Commission's action in promulgating these rules was substantively authorized by the Esch Act and procedurally acceptable under the Administrative Procedure Act.


The Court reversed the judgment.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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