Baltimore & Ohio Railroad v. Interstate Commerce Commission

Background

A railroad company sued to annul an Interstate Commerce Commission order that required carriers covered by the 1907 Hours of Service Act to file monthly sworn reports showing instances when train employees had been on duty longer than the law allowed. The carrier said the Commission was seeking evidence for penalty suits and argued the reporting requirement violated the Fourth Amendment against unreasonable searches and the Fifth Amendment protection against self‑incrimination. The Circuit Court sustained a demurrer and dismissed the bill, and the company appealed.

Reasoning

The Court first held the statute applies only to carriers and to employees connected with interstate, territorial, District, or foreign transportation as defined in the law. It concluded Congress may limit hours of service for those employees because hours relate directly to safety. The Court rejected the claim that the statute was unconstitutionally vague (including the “except in case of emergency” proviso). It also found that a 1910 amendment gave the Commission authority to require periodic or special reports under oath, and the Commission’s forms (including a special oath when no excess service occurred) and direction that reports be made by the carrier’s secretary fit within that authority. Finally, the Court held the Fourth Amendment did not apply and that a corporation cannot invoke its officers’ personal Fifth Amendment privilege to avoid ordered corporate reporting.

Real world impact

The decision leaves the federal hours‑of‑service law intact and lets the Commission demand monthly sworn reports about excess service from carriers engaged in the covered commerce. Carriers must keep and produce records and may face penalty suits based on information the Commission furnishes to district attorneys. Individual officers cannot block corporate reporting by claiming a personal privilege.