Georgia Railway & Power Co. v. Mayor of College Park
Headline: City annexation cannot force a 1905 five-cent streetcar fare; Court reverses state ruling and protects the company’s right to charge the same fare both directions, blocking forced free transfers.
Holding: The Court reversed the state decision, held the 1905 contract requires the same five-cent fare both directions between College Park and Atlanta, and ruled applying that fare to newly annexed territory impairs the contract.
- Protects the company’s right to charge five-cent fares both directions.
- Prevents the commission’s order forcing free transfers for College Park riders.
- Limits how municipal annexation can expand fare obligations under the 1905 contract.
Summary
Background
A private electric railway company and the city government in Georgia disputed who could set fares on a line running between College Park and Atlanta. In 1905 the company obtained a contract allowing it to convert a single track to a double track and limiting the fare to no more than five cents for passage from the southern limits of College Park to a central point in Atlanta. Later the city extended its boundaries to include part of the line that had been outside the municipality. A state regulatory commission ordered the company to issue free transfers to College Park passengers. The state courts handled this case with a related one and reached a decision the company appealed to the Court.
Reasoning
The Court considered whether the city’s expansion and the commission’s order changed the company’s 1905 contract rights. Relying on a related case, the Court held that applying the five-cent fare to the newly annexed territory would impair the company’s contractual obligation. The Court also rejected the commission’s order requiring free transfers to College Park patrons as erroneous. The Justices agreed with the state courts’ reading that the contract required charging the same fare in both directions between College Park and Atlanta, noting the company had done so for many years.
Real world impact
The ruling protects the company’s long-standing fare arrangement and removes the agency order for free transfers. It limits how municipal annexation can change fare obligations under this contract. The case was reversed and sent back to state court for further proceedings consistent with this opinion.
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