Southern Railway Co. v. King
Headline: Affirms that Georgia law requiring trains to sound a whistle and check speed at crossings may be enforced because the railroad failed to show how the rule unlawfully burdened interstate travel.
Holding:
- Allows states to enforce local train-safety rules absent specific factual proof of interstate burden.
- Requires railroads to plead and prove specific facts before claiming a state law burdens interstate commerce.
- Leaves the statute’s ultimate constitutionality unresolved until facts are shown.
Summary
Background
A widow, Josephine King, sued a railroad for her husband’s wrongful death at a highway-rail crossing, and Inez King sued for injuries from the same incident. Both suits alleged the railroad violated a Georgia law (§2222) requiring posts 400 yards from crossings and that engineers blow the whistle and “check and keep checking” speed so a train could stop if someone was on the track. The cases went to federal court, verdicts were entered against the railroad, and appeals followed to the Supreme Court.
Reasoning
The railroad argued the Georgia law unlawfully burdened interstate commerce and so could not apply to interstate trains. It filed an amended answer claiming compliance would make interstate service, including carrying the mails, impossible, and tried to offer proof about many crossings and delay times. The trial court struck the amendment and excluded the offered testimony. The Supreme Court agreed the amendment contained only conclusions and failed to allege the specific facts needed to show the law’s unreasonable effect on interstate commerce, so the demurrer was properly sustained and the judgments stood.
Real world impact
The decision lets state safety rules like Georgia’s be enforced unless a carrier clearly pleads and proves how a rule unreasonably burdens interstate service. Because the Court resolved a pleading and proof issue, it did not finally decide whether the statute is unconstitutional on the merits; that question would require the specific factual showing the railroad failed to provide.
Dissents or concurrances
Justice Holmes (joined by Justice White) dissented, arguing the railroad’s factual allegations and its offer of proof should have been heard, and that excluding them denied a fair chance to decide the constitutional question.
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