Boyce Motor Lines v. US case brief summary

Boyce Motor Lines v. US case brief summary1952

 

a)       Congress gave the Interstate Commerce Commission the power to make their own regulatory rules. They enacted a rule regarding the transportation of explosives which read as follows:

(1)     “Drivers of motor vehicles transporting an explosive, inflammable liquid, inflammable compressed gas, or poisonous gas shall avoid, so far as practicable, and, where feasible, by prearrangement of routes, driving into or through congested thoroughfares, places where crowds are assembled, street car tracks, tunnels, viaducts, and dangerous crossings.”

b)      Whoever “knowingly” violates the statute shall be subject to fines or imprisonment or both. The ∆ drove a truck with explosives through the Holland Tunnel, resulting in an explosion that injured about sixty people. The question was then whether the ICC regulation was a valid rule. The majority found that the regulation was valid, in light of the presence of a culpable intent requirement and the fact that the agency adopted the regulation after much study and consultation with the trucking industry. The case was then remanded to determine if there were practicable alternative routes and/or if the driver fulfilled the element of knowledge. The dissent felt that the regulation was “unworkable” and “indefinite.”

c)       When delegating a crime-making power to an agency, there is a higher degree of notice required

d)      This regulation is necessarily vague – there needs to be an element of discretion available for the drivers

(1)     There’s also a built in level of discrimination in the prosecution’s choices and the judicial sentencing