United States v. Baltimore & Ohio Southwestern Railroad

Background

A federal law allowed the Secretary of Agriculture to quarantine parts of a State when contagious livestock disease was found. The Secretary quarantined Kentucky for scabies and sent notices and rules to transportation companies. Sheep were shipped from Kentucky and arrived in Cincinnati. The cars were delivered to the defendant, which moved the sheep to the Union Stock Yards. The indictment said the sheep lacked required placards and charged the defendant with receiving or transporting animals "from" a quarantined State.

Reasoning

The Court asked whether the law covers a carrier that only receives and moves animals in a State other than the quarantined State. The Court held that criminal statutes must be read strictly. The crime requires receiving animals for transportation in the quarantined State or transporting them from that State into another. Because the defendant received and moved the sheep in Ohio, the statute's elements were not met and the indictment failed.

Real world impact

Prosecutors must show a carrier took possession of animals in the quarantined State or moved them from that State to bring criminal charges under this law. Companies that only handle animals after they reach another State are less likely to face criminal punishment under this statute. The opinion notes the Secretary must give notice only to carriers doing business in or through the quarantined State, supporting protection for distant carriers who may not receive notice. The decision leaves public-health tools and civil remedies available to address disease spread.

Dissents or concurrances

Some lower federal courts had reached opposite conclusions, but the Supreme Court affirmed a narrower interpretation.