Chicago, Indianapolis & Louisville Railway Co. v. United States

Background

Four steam railroads sued to set aside an Interstate Commerce Commission order that found they were discriminating against a nearby electric passenger railroad that also carried freight. The electric line (the South Shore) connected directly only to one steam railroad at Michigan City. That steam carrier was ordered earlier to provide joint routes and reciprocal switching; the other three steam roads refused to make similar arrangements, leaving the electric line at a disadvantage when handling interstate carload traffic.

Reasoning

The key question was whether the Commission could require the steam railroads to stop a discriminatory practice even though some lacked direct physical connections with the electric line. The Court said direct physical connection was not required, that the order did not force expansion of service but left the carriers room to choose how to comply, and that the Commission’s factual finding that the steam roads treated each other alike but not the electric line was entitled to deference. The Court rejected the railroads’ claim that the order took their property without due process and affirmed the Commission’s jurisdiction, noting the Commission found the electric line was engaged in general freight transportation.

Real world impact

The ruling requires the steam railroads to remove practices that blocked the electric carrier from fair interchange and access to interstate freight handling at Michigan City. Shippers and industries there should gain more access to routes and competitive handling. Because the Commission’s factual findings control the outcome here, the decision upholds regulatory power to correct carrier-to-carrier discrimination.