Chicago, Milwaukee & St. Paul Railway Co. v. State Public Utilities Commission
Headline: State commission order cutting a railroad's 40 cent coal rate for a 12-mile local haul is upheld, letting Illinois regulators lower intrastate shipping charges for local growers while federal oversight does not block it.
Holding:
- Confirms state regulators can set lower intrastate rail rates for short local hauls.
- Allows local producers to benefit from reduced shipping charges on short-distance coal deliveries.
- Limits federal agency power over purely intrastate rate decisions in this context.
Summary
Background
A flower grower in Illinois (Poehlmann Bros. Company) shipped coal and manure to its greenhouse at Morton Grove, a station about three miles northeast of Chicago. The coal and manure moved by rail from Galewood (inside Chicago) to Morton Grove, a haul of about 12 miles. The railroad published and charged 40 cents a ton for that intrastate haul. In 1913 the state warehouse commission found that 20 cents a ton for coal and 25 cents for manure were just and ordered the railroad to change its charges. Illinois trial and supreme courts affirmed the commission’s order.
Reasoning
The railroad argued the 12-mile charge was part of larger through (interstate) rates and so the state action conflicted with federal control and the Interstate Commerce Act. The Court looked at the record and found the coal at issue both originated and ended in Illinois, so the state could treat the 12-mile segment as an intrastate rate. The Court noted a different federal complaint had involved coal from West Virginia and that the federal commission’s report was not before the Court. Citing earlier decisions that preserve a field for state regulation of intrastate rates, the Court concluded the state commission’s order did not unlawfully interfere with interstate rate regulation.
Real world impact
The ruling leaves in place the lower intrastate rate the state commission set and affirms that, in this factual setting, Illinois regulators may adjust short local rail charges without being overridden by federal rate decisions. The judgment was affirmed.
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