Michigan Central Railroad v. Michigan Railroad Commission

Background

Merchants in two nearby Michigan villages asked the state railroad commission in 1908 to require a large steam railroad and a local electric interurban line to connect tracks and exchange cars, freight, and passengers at Oxford. The commission found a physical connection was practicable, estimated modest construction costs, and ordered the two companies to connect and interchange traffic. The steam railroad built the physical connection under protest but refused to hand over cars or carload freight to the interurban for transport along its line. The state courts enforced the commission’s order by issuing a mandamus directing interchange for intrastate traffic.

Reasoning

The Court reviewed whether the state commission had authority and whether the order violated the Constitution. It accepted the state court’s findings that the order applied only to intrastate traffic, that the interchange was practicable, and that reasonable compensation and protections for equipment existed. The opinion rejected arguments that the order deprived the railroad of property without due process or unlawfully burdened interstate commerce, explaining that vehicles used for public transportation are subject to reasonable state regulation for intrastate service and that the order need not be read to interfere with interstate needs.

Real world impact

The decision requires the steam railroad to permit the interurban to haul cars and deliver intrastate freight and passengers via the new connection, benefiting local shippers and travelers. It affirms a state agency’s power to order track connections and interchange for intrastate commerce while preserving the rule that state action must not obstruct interstate commerce.