United States v. Baltimore & Ohio Railroad

Background

A meatpacker (Swift & Company) wanted interstate livestock delivered to its private siding in Cleveland. Five railroads, using a spur that runs through a 1,619-foot segment owned by the Cleveland Union Stock Yards Company, had stopped delivering livestock there after a 1935 contract change and costly fee demands. Swift complained to the Interstate Commerce Commission, which ordered the railroads to resume livestock deliveries and set tariffs; a federal district court blocked enforcement, and the case reached the Supreme Court.

Reasoning

The main question was whether a non‑carrier track owner could use its ownership and contract rights to force railroads to refuse or condition deliveries in a way that discriminated against shippers. The Court relied on the Interstate Commerce Act’s broad definitions treating tracks in use by a carrier as subject to regulation regardless of ownership. It concluded Congress meant to prevent discrimination even if a private owner tried to impose restrictive conditions. The Court held the Commission had authority to order the railroads to stop the discriminatory practice and found no unconstitutional taking or denial of due process in enforcing the Act.

Real world impact

The decision means private owners of trackage cannot enforce contract terms that cause discriminatory rail practices under the Interstate Commerce Act. Railroads named in the order must deliver interstate livestock to Swift’s siding and establish appropriate tariffs. The Court left open related contract and financial questions, like cancellation rights and private remedies, which it did not decide.

Dissents or concurrances

One Justice dissented, arguing the Commission exceeded its power and that the injunction against enforcing the Commission’s order should have been affirmed.