Hampton v. St. Louis, Iron Mountain & Southern Railway Co.

Background

A railroad company sued to stop the State and its Railroad Commission from bringing legal actions and penalties under Arkansas laws that require rail carriers to furnish freight cars on demand. The Commission’s order copied the 1907 law’s wording: a shipper who applied in writing must be provided a car within six days. A late clause in the law said interstate railroads must furnish cars for interstate shipments the same as intrastate shipments. The state trial court held the 1907 law unconstitutional and made a temporary injunction permanent.

Reasoning

The Court reviewed two main objections: that the clause about interstate shipments invalidated the whole law, and that the law imposed an absolute duty to furnish cars with no possible excuse. The Court said the interstate clause could simply forbid discrimination against interstate demands, and that Arkansas’s own courts had framed the rest of the law as a workable system for intrastate regulation. The Court also held the duty was not truly absolute because state courts allow reasonable defenses (for example, unusual congestion or unavoidable detention of cars). Most importantly, the railroad had not shown that the law, as applied, actually restrained interstate commerce.

Real world impact

Because the railroad presented conjectural objections rather than proof of an actual burden on interstate commerce, the Court reversed the injunction and sent the case back with directions to dismiss the bill. The ruling leaves the Arkansas statute largely intact while confirming that carriers may raise reasonable excuses in enforcement cases, and that federal relief requires a concrete showing of interstate harm.