Erie Railroad v. Purdy

Background

A private citizen sued the Erie Railroad, a New York corporation, in twenty-one cases to collect penalties under New York’s Mileage Book laws of 1895 and 1896. At trial the railroad argued the law interfered with interstate commerce. The New York courts treated the law as applying only to travel wholly inside the State and ruled for the plaintiff. The railroad then asked the U.S. Supreme Court to review the state-court judgment and, for the first time in that petition, invoked the Fourteenth Amendment.

Reasoning

The central question was whether the Supreme Court could review the state judgment on the Fourteenth Amendment claim. The Court found the Fourteenth Amendment argument had not been distinctly raised in the trial court; state courts had only addressed the commerce point. Because the constitutional claim was not properly presented below, the Supreme Court concluded it lacked authority to review that federal question. The Court therefore dismissed the writ of error for want of jurisdiction.

Real world impact

The dismissal leaves the New York rulings and the Mileage Book law in place for now and does not decide whether the Fourteenth Amendment would apply. The decision underscores that parties must clearly raise federal constitutional claims in trial court to preserve them for review by higher courts. This outcome is procedural: it denies review but does not resolve the constitutional merits.