United States v. Chicago Heights Trucking Co.

Background

Forty-one interstate motor carriers operating under the Federal Motor Carrier Act proposed special tariffs that would give lower rates to freight forwarders. Forwarders gather many small shipments, assemble them into truck-loads or carloads, and arrange further delivery; the tariffs would apply when shipments were consolidated or immediately reshipped. The Interstate Commerce Commission cancelled those proposed tariffs as unlawfully discriminatory, and a three-judge District Court set the Commission’s order aside, prompting this appeal.

Reasoning

The central question was whether the special tariffs would unlawfully give forwarders an advantage over other shippers. The Court reviewed the same evidence as the Commission and held that the Commission’s judgment that the tariffs would operate primarily for the forwarders’ benefit and create unfair preferences was supported by ample evidence. The Court explained that Congress entrusted the Commission to decide when different treatment of similar transportation services becomes unjust discrimination, and a reviewing court should not substitute its judgment for the Commission’s informed judgment.

Real world impact

The ruling upholds the Commission’s authority to cancel carrier rates that in practice favor a particular group of shippers. Forwarders who relied on lower consolidated rates will find those special tariffs blocked, and carriers cannot give such preferential rates if the Commission finds they create undue preference. The Court reversed the lower court and dismissed the bill, making the Commission’s decision conclusive.

Dissents or concurrances

Two Commissioners dissented below, arguing the proposed rates were lower than some but not all local rates and presenting detailed defenses for the tariffs. Their views emphasized different inferences from the same evidence.