Interstate Consolidated Street Railway Co. v. Massachusetts

Background

A street railway company in Massachusetts refused to sell half‑fare tickets for pupils going to and from public schools as the state law required. At trial the company admitted refusing to comply but argued the law violated the Fourteenth Amendment by denying equal protection and taking property without just compensation or due process. The company offered proof that its regular fare was five cents while its cost per passenger was about 3.86 cents (4.10 cents with taxes), and that pupils made up a considerable share of riders; the trial court excluded that evidence. The state courts convicted the company and the case reached this Court.

Reasoning

The core question was whether Massachusetts could require railways to carry schoolchildren for half the usual fare. The Court affirmed the state courts. A majority said the law bound the company because the statute was in force when the company accepted its charter, so the company had effectively consented to that duty. Justice Holmes also explained that, apart from consent, the requirement could be justified under the state’s power to enact laws for public welfare, allowing modest burdens on property for public purposes. The Court found the offered evidence insufficient to show the law imposed a clearly excessive burden that would violate the Constitution.

Real world impact

The ruling allows Massachusetts and similar states to require street railways to give half fares to school pupils in similar circumstances. It means companies that accept charters under existing laws have limited ability to avoid duties the law prescribes. The decision affirms that modest public‑purpose regulations can survive constitutional challenge.

Dissents or concurrances

Justice Harlan agreed in the judgment, noting he would affirm because the record did not show a denial of equal protection or a taking without due process.