Interstate Commerce Commission v. Chicago, Burlington & Quincy Railroad

Background

A private complainant challenged freight rates and the Interstate Commerce Commission held that through class rates from Chicago and St. Louis to Denver were unreasonably high and discriminated in favor of Missouri River cities. The Commission gave detailed figures and ordered rail carriers to reduce and maintain specified class rates for a two-year period. Several western railroad companies sued to stop enforcement and obtained a preliminary injunction from the circuit court, supported by affidavits that warned the rate changes would deeply affect western commerce and the railroads’ revenues.

Reasoning

The Supreme Court considered the same general questions that had been decided in two companion cases and treated the present appeal on that authority. The Court reviewed the Commission’s findings that the through rates were excessive and discriminatory, and noted the Commission’s assessment that reasonable reductions would not unduly reduce defendants’ revenues. Relying on its rulings in the related cases, the Court concluded the circuit court should not have issued the preliminary injunction and therefore reversed the decree that had kept the ordered rates from taking effect.

Real world impact

The Court’s decision requires that the injunction be set aside and the railroad companies’ bill dismissed, allowing the Commission’s ordered rate reductions to be enforced. That enforcement will compel carriers to charge the lower through rates specified by the Commission and will immediately affect freight pricing and competition between Missouri River cities and Denver. The ruling was based on the Court’s disposition of the companion cases and ends the temporary blocking of the Commission’s order.