Maislin Industries, U. S., Inc. v. Primary Steel, Inc.

Background

A trucking company and its bankruptcy estate (Maislin and its subsidiary Quinn) negotiated lower shipping rates with a steel company (Primary) but never filed those rates with the Interstate Commerce Commission (ICC). After Maislin declared bankruptcy, the trustee audited accounts and billed Primary for the difference between the filed tariffs and the lower negotiated bills. Primary invoked the ICC’s new “Negotiated Rates” policy, which had allowed the Commission to refuse collection of undercharges in such situations, and the ICC ruled for Primary.

Reasoning

The Supreme Court addressed whether the ICC could decline to enforce filed tariffs because a lower unfiled rate had been negotiated. The Court relied on the long-established “filed rate” requirements in the statute and earlier cases, held that the ICC’s Negotiated Rates policy conflicted with the Interstate Commerce Act, and concluded the agency lacked authority to excuse payment of filed rates simply because a lower unfiled agreement existed. The Court reversed the Eighth Circuit and remanded for proceedings consistent with this ruling.

Real world impact

The decision affects motor carriers, shippers, and bankruptcy estates by reinforcing that filed tariffs govern collection unless the Commission itself finds the filed rate unreasonable. Carriers and bankruptcy trustees are more likely to recover filed undercharges; shippers who relied on private, unfiled agreements face increased exposure. The ruling does not decide whether the specific filed tariffs were reasonable, leaving that issue open on remand.

Dissents or concurrances

Justice Stevens (joined by the Chief Justice) dissented, arguing the ICC reasonably interpreted the statute in light of post-1980 deregulation and industry changes and deserved deference; Justice Scalia concurred, emphasizing the statute’s text forbids charging rates other than those filed.