Chicago, Burlington & Quincy Railroad v. Railroad Commission

Background

A resident of Cochrane, a Wisconsin village of about 260 people, petitioned the state railroad commission complaining of poor local train service. A 1911 Wisconsin law required villages with a post office and 200 or more residents to have at least one daily passenger stop, and two stops if the railroad ran four or more passenger trains each way. The commission ordered the railroad to provide extra stops at Cochrane. The railroad, which ran mostly interstate trains and carried about 90% interstate traffic, challenged the order as an unlawful interference with interstate commerce. State courts upheld the commission’s order under the statute and treated the law as leaving no discretion to regulators.

Reasoning

The Court addressed whether a rigid, statewide formula could force changes to interstate train schedules. It found the law arbitrary because it tied required stops to village population and train counts rather than to demonstrated local need or specific evidence. The record showed Cochrane’s passenger revenue was small (about $1,751.63 for the year) while the statute could impose heavy costs (an estimated $84,000 annually) by forcing added service. Applying prior decisions, the Court held that the blanket requirement unreasonably burdened interstate train service and was therefore invalid.

Real world impact

The ruling prevents states from imposing one‑size‑fits‑all stop mandates that compel railroads to change interstate schedules or run extra trains. States remain able to require reasonable local accommodations after case‑specific investigation, but not by inflexible statewide rules.

Dissents or concurrances

A justice in the state court dissented, arguing that legislative judgment about "convenience" is broad and affords the State considerable discretion.