St. Louis Southwestern Railway Co. v. Missouri Pacific Railroad

Background

A Missouri railroad company asked an Arkansas railroad commission to fix the place and terms where it would cross an industrial spur owned by another railroad at grade in North Little Rock. Both railroads carried interstate traffic. The state commission denied the application without giving reasons. The state trial court ordered the commission to fix the crossing, and the Arkansas Supreme Court affirmed, treating the proposed track as a local spur that did not need a federal certificate. The other railroad argued the track was an extension into new territory and that federal law should have prevented the state action without prior federal approval.

Reasoning

The key question was whether the state commission had to refuse to act until the railroad obtained a federal certificate showing the extension was in the public interest. The Court said no: the Arkansas statute giving the commission exclusive power to set crossing points and terms was not displaced. If a railroad believes the proposed line is an unlawful interstate extension, federal law provides a remedy by injunction in federal court under the Transportation Act; that remedy is the proper way to decide whether federal approval is required. The Court noted that the state order did not authorize construction or use and would not prevent later federal action.

Real world impact

This decision lets state railroad regulators continue to set where and how crossings are installed and protected, even when the tracks may serve interstate commerce. Railroads that think a proposed line is an interstate extension must go to federal court or to the federal commission for an injunction or certificate review rather than block a state crossing proceeding. The ruling does not finally decide whether the track in this case is a spur or an extension; that issue can be determined later without being prejudiced by the state commission’s order.