Houston & Texas Central Railroad v. Mayes

Background

A Texas law required railroads to supply a requested number of freight cars at a named station within a set number of days, with shippers depositing one-fourth of the freight charge. If the railroad failed to deliver, it faced a $25 per-car daily penalty, and similar fines applied if shippers or consignees delayed loading or unloading. The dispute arose when a shipment bound for Oklahoma (an interstate shipment) was delayed and the railroad was fined under this statute.

Reasoning

The Court examined whether applying this absolute supply-and-penalty rule to interstate shipments improperly interfered with the national power to keep interstate commerce free. The majority concluded the law left no room for ordinary interruptions—such as congestion, wrecks, weather, or temporary detention in other States—and so imposed an unreasonable burden. Because the statute allowed heavy, automatic penalties without adequate exceptions, the Court held it could not be enforced as applied to interstate commerce.

Real world impact

The decision prevents states from enforcing absolute delivery schedules with rigid penalties against railroads transporting goods between States. Shippers can still pursue actual damages when harmed, but arbitrary statutory fines tied to fixed deadlines cannot be imposed on interstate shipments. The ruling protects carriers from severe penalties for delays beyond their control while leaving states able to enact reasonable local safety and service rules.

Dissents or concurrances

Three Justices disagreed, as noted in dissent, signaling some disagreement about how far state rules may reach into interstate transportation, but the majority’s view governs this case.