Herndon v. Chicago, Rock Island & Pacific Railway Co.
Headline: Court upholds injunction blocking Missouri law that would force interstate passenger trains to stop at small junctions and bars state threats to revoke out-of-state railroads’ business licenses for suing in federal court.
Holding: The Court affirmed the lower court’s injunction, ruling that Missouri could not force interstate through trains to stop at Lathrop and could not revoke a foreign railroad’s state business rights for suing in federal court.
- Allows interstate through trains to skip mandatory junction stops with adequate facilities.
- Prevents states from revoking foreign railroads’ business rights for using federal courts.
Summary
Background
An Illinois railroad company that runs trains through Missouri sued a county prosecuting attorney and the Missouri secretary of state to stop enforcement of two 1907 Missouri laws. One law required passenger trains to stop at junctions and threatened $25 daily penalties; the railroad said its fast interstate trains do not stop at the small town of Lathrop and that forcing stops would harm interstate traffic and mail service. The other law allowed the State to revoke a foreign corporation’s license and impose large fines if the company sued a Missouri citizen in federal court or removed a state case to federal court.
Reasoning
The Court considered whether the State could force interstate through trains to stop at Lathrop and whether it could strip a foreign corporation’s right to do business for using federal courts. Relying on prior decisions, the Court treated the stop rule as aimed at convenience, not safety, and held that requiring stops when adequate local service already existed would unlawfully burden interstate commerce. The Court also applied principles from related cases at the same term to conclude that the revocation-and-penalty law could not be used to punish a corporation for resorting to the federal courts.
Real world impact
The decision lets the railroad continue operating through interstate trains without compelled stops at Lathrop when adequate passenger facilities and connections exist, and it protects out-of-state corporations from losing state business rights for suing or removing cases to federal court. The ruling affirms limits on state laws that interfere with interstate transportation and access to federal courts.
Dissents or concurrances
No dissent is reported; the Chief Justice is noted as concurring in the result.
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