Interstate Commece Commission v. Northern Pacific Railway Co.

Background

A railroad company that owns the Northern Pacific line sued to stop an order by the Interstate Commerce Commission that would force through passenger routes and joint rates so Union Pacific trains could use the Northern Pacific track between Portland and Seattle. The Commission’s order covered one-way passenger travel, not round trips or freight. Lower circuit judges had granted an injunction against the order, and the case reached this Court on appeal. The record shows existing ticket practices, including a Union Pacific coupon that passengers must exchange at Portland and extra charges for Pullman service.

Reasoning

The key question was whether the Commission could require a new through route when a reasonable and satisfactory through route already existed. The statute allows the Commission to act only if no reasonable route exists. The Court said that condition must be read in its natural sense and that courts can examine whether a reasonable route actually exists. The evidence showed the Northern Pacific route was shorter, ran faster on average, and provided equal passenger accommodations. The Commission had relied mainly on passengers’ preference for a southern route and scenic or settlement reasons, but the Court held those preferences did not prove that no reasonable route existed. Because the Commission exceeded its statutory power, the Court affirmed the injunction protecting the Northern Pacific route.

Real world impact

The decision prevents the Commission from forcing joint through passenger routes when an adequate through route already serves the travel. It preserves the Northern Pacific’s control of its segment and limits the Commission’s power in similar route disputes. Passengers, rail companies, and terminals affected by such orders will have to show a genuine lack of a reasonable route before the Commission can impose shared use.

Dissents or concurrances

The opinion notes a dissent by the Commission Chairman who warned of injustice from denying a second route, but the Court found the statute barred that result.