New York Central & Hudson River Railroad v. Board of Chosen Freeholders of the County of Hudson

Background

A railroad company operating the West Shore Railroad ferries between New Jersey (Weehawken) and New York challenged two 1905 Hudson County ordinances that set foot-passenger and round-trip fares. The railroad argued the county rules unduly interfered with interstate business carried on by the ferries. A New Jersey trial court supported the railroad, the Court of Errors and Appeals later reversed, and the dispute reached this Court for review.

Reasoning

The central question was whether Congress had already taken control of railroad ferries so that states could no longer regulate them. The Court reviewed earlier ferry and bridge cases and focused on the Act to Regulate Commerce (February 4, 1887). That statute expressly includes “bridges and ferries” used with railroads. The Court concluded this language shows Congress meant to cover railroad-operated ferries, so federal authority reaches the whole interstate ferry business and leaves no room for state fare rules to apply to that interstate commerce.

Real world impact

The decision prevents local governments from enforcing passenger-rate ordinances against railroad-operated interstate ferries. It confirms that when Congress acts to regulate railroad ferries, federal law displaces conflicting state control. The Court reversed the earlier state-court judgment and sent the case back for further proceedings consistent with this ruling.