Chesapeake & Ohio Railway Co. v. Conley

Background

A large railroad company sued West Virginia officials to block a 1907 law that set passenger fares at two cents per mile. The law included a five-cent minimum, half fare for children under twelve, exceptions for short lines under fifty miles, and fines of $50 to $500 for violations. The state trial court and the West Virginia Supreme Court of Appeals sustained the law, and the railroad brought the case for review.

Reasoning

The Court considered three main complaints: that the fines were excessive, that the law unfairly singled out certain railroads, and that it improperly interfered with interstate commerce. The Court accepted the state court’s interpretation that the penalty clause did not apply while the railroad was pursuing a good-faith court challenge. It found the classification by length and operation reasonable and the wording about “control, management or operation” to mean railroads actually operated as one. The Court also treated the statute as regulating only traffic entirely within West Virginia (not crossing state lines), which states may control.

Real world impact

The decision leaves the two-cent fare law in force for intrastate passenger trips in West Virginia. Railroads operating wholly inside the State must follow the rate or face fines, though a company pursuing a good-faith lawsuit can avoid immediate penalties while the issue is litigated. The ruling affirms states’ power to set in-state transportation rates under the circumstances described.