Railroad Commission of Ohio v. Worthington, Receiver of Wheeling & Lake Erie Railroad Company

Background

A bill was filed in federal court to stop the Ohio Railroad Commission from enforcing a seventy‑cent per ton rate on “lake‑cargo coal” moved from the No. 8 coal field in eastern Ohio to the ports of Huron and Cleveland for loading on lake vessels. The complainant was the railroad (through its receiver) and coal operators. Lower courts granted and then affirmed a permanent injunction against the commission’s order. The Circuit Court found facts about how the coal was classified, shipped to Huron, loaded into vessels, and then carried beyond Ohio.

Reasoning

The central question was whether the state commission could set a rate that applied when coal was loaded at Ohio ports and carried by vessel to points outside the State. The Court explained that regulation of interstate commerce is a federal power and that the seventy‑cent rate applied only to coal actually placed on vessels for shipment beyond Ohio. Because the rate covered the rail movement to the port plus the loading and trimming necessary for the onward journey, it directly regulated interstate carriage. The Court therefore held the commission had exceeded state authority and affirmed the injunction against enforcing the rate.

Real world impact

The ruling prevents the Ohio commission from applying its seventy‑cent rate to coal shipments that form part of interstate transport to other States or Canada. It protects rail carriers and shippers from state rate rules that would control parts of a continuous interstate shipment and reinforces federal control over interstate freight rates.