Northern Pacific Railway Co. v. Washington Ex Rel. Atkinson

Background

In July 1907 a railroad company ran a train in Washington and let members of the train crew work more than sixteen consecutive hours. Congress had passed the Hours of Service law on March 4, 1907, but that law said it would not take effect until one year later. The State of Washington had its own hours law that became effective June 12, 1907, with similar prohibitions. The State’s Attorney General sued the railroad under the state law, the trial court awarded a $1,000 penalty, and the Washington Supreme Court affirmed that judgment.

Reasoning

The central question was whether Washington could apply its hours rule to a train engaged in interstate commerce while Congress had passed a federal hours law that would take effect later. The Court held Congress’s act alone removed the matter from state control once Congress legislated on it. The opinion explained that treating the federal law as a statute that is inoperative until its effective date would wrongly allow state laws to override the federal assertion of authority. The Court also said Congress’s one-year delay was meant to let railroads adjust, not to preserve state regulatory power. The Court reversed the state court’s judgment.

Real world impact

Because of this decision, a state may not enforce its own hours-of-service rules against interstate trains after Congress has legislated on the subject, even if the federal law’s enforcement is postponed. In this case, the railroad’s liability under the state penalty could not stand. The case is sent back to the lower court for further steps consistent with the Supreme Court’s ruling.