Buck v. Kuykendall
Headline: State law blocking new interstate bus lines is struck down, allowing out-of-state motor carriers to use federally aided highways and preventing states from denying routes to avoid competition.
Holding: The Court reversed and held that a state may not bar interstate motor carriers from using public highways through a license system that primarily excludes competition and thus obstructs interstate commerce and federal highway purposes.
- Stops states from denying interstate bus routes merely to limit competition.
- Protects interstate motor carriers’ access to federally aided highways.
- Limits state power to control who may run services on interstate routes.
Summary
Background
A Washington citizen, Buck, wanted to run an auto stage line for through interstate passengers and express between Seattle and Portland. He held the Oregon license and followed Washington vehicle laws, but Washington required a state certificate saying "public convenience and necessity" justified the route and denied his application because other carriers already served the route. Buck sued the state official who enforces the certificate rule to stop enforcement and was denied relief in federal court.
Reasoning
The Court considered whether the Washington law as applied to interstate carriers conflicted with the Constitution and federal highway laws. The Court assumed ordinary safety and road-use rules are allowed, but found this provision aimed mainly at blocking competition by deciding who may operate, not how to use the roads. By letting state officials refuse permits based on adequacy of service, the statute regulated interstate commerce in a way the Court said obstructs it and undermines Congress’s purpose in funding interstate highways. The Court therefore reversed the dismissal and rejected the State’s attempt to justify the restriction.
Real world impact
The decision prevents states from using certificate rules to exclude interstate motor carriers purely to limit competition on federally aided highways. Interstate bus and express operators are protected from state refusals that primarily aim to protect local interests rather than safety. The ruling enforces the federal interest in keeping funded interstate highways available for interstate commerce.
Dissents or concurrances
Justice McReynolds dissented and wrote a separate opinion in this case, though the Court’s main opinion reversed the lower court.
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