United States v. Baltimore & Ohio Railroad

Background

A railroad company operated a bridge built in 1871 between Parkersburg, West Virginia, and Belpre, Ohio, under a law passed in 1862 that set the bridge's dimensions. The United States sued in equity and asked a court to block reconstruction and require a wider channel span; the district court and the Circuit Court of Appeals refused the Government’s request, concluding the company had the right to keep and repair the bridge. Later the Secretary of War, relying on an 1899 river-and-harbor law, ordered the removal of a pier and conversion of two spans into one large channel span, and the company was indicted for failing to obey that order.

Reasoning

The key question was whether the earlier federal court decision prevented the Secretary and the Government from enforcing the 1899 order. The trial judge instructed the jury to acquit based on the prior decree, explaining that a previous final decision on the same issue bars re‑litigation. The Supreme Court agreed that the equity judgment proved the Secretary had no power over the bridge under the circumstances, so the criminal prosecution could not proceed.

Real world impact

The decision protects property holders who rely on long‑standing, court‑recognized rights to structures built under older statutes by preventing later executive enforcement on the same point. It also limits the Government’s ability to use the 1899 act to force alterations when a court has already decided the issue, and leaves open whether Congress could directly change the law to require removal or alteration.