Interstate Commerce Commission v. Stickney

Background

A group of railroad companies charged a $2 terminal fee per car to deliver live stock to the Union Stock Yards in Chicago. The Interstate Commerce Commission ordered the railroads to stop charging more than $1 per car for deliveries from points outside Illinois. The dispute followed earlier litigation and relied on filings the railroads made under the Hepburn Act, which required carriers to list terminal charges separately. The railroads’ published tariffs and affidavits showed the $2 item as a distinct terminal charge, and the Union Stock Yards Company operated as an independent corporation.

Reasoning

The central question was whether the $2 terminal charge was unreasonable. The Court said a carrier may lawfully charge separately for terminal services, and that a terminal charge that is reasonable on its own cannot be condemned simply because, when added to earlier transportation charges, the total may burden shippers. The record showed delivery of live stock cost about $2 per car for some defendants and that average handling cost for all carload freight was much higher, supporting the reasonableness of the $2 charge. Because the terminal fee appeared just and reasonable standing alone, any complaint about excessive total cost should target the earlier through rates instead of the terminal charge.

Real world impact

The ruling leaves the $2 per-car delivery fee in place for live stock at the Union Stock Yards and requires shippers or regulators who believe total charges are unfair to challenge prior transportation rates. The lower court’s order was affirmed, so the commission may not enforce the $1 cap in this case.