Bacon v. Rutland Railroad

Background

A Vermont railroad company sued the state Public Service Commission to stop enforcement of an order about its passenger station at Vergennes. The railroad said the order violated the Fourteenth Amendment. The company filed a bill in equity in federal court and asked for an injunction. The Commission argued the case should not proceed in federal court because the railroad had not taken the statutory appeal to the Vermont Supreme Court under sections 4599 and 4600. The District Court denied the Commission’s motion to dismiss and issued the injunction the railroad requested.

Reasoning

The Court considered whether Vermont’s appeal process required the railroad to exhaust state remedies before a federal suit. It compared this case to Prentis v. Atlantic Coast Line Co., where the state supreme court could act with legislative power and federal review was postponed. Here, the Vermont statute plainly gives the state court a judicial role: to correct errors, affirm or reverse, and remand with mandates. The opinion notes Vermont’s own Supreme Court treats this remedy as judicial. Because the remedy is judicial rather than legislative, the railroad was entitled to go straight to the federal courts to assert its Fourteenth Amendment claim. The Court therefore affirmed the decree allowing the injunction.

Real world impact

The decision lets regulated companies seek federal-court relief when state appeal routes are judicial in character. It makes it easier to block state agency orders alleged to violate constitutional rights while federal courts decide the matter. The ruling focuses on procedure and does not resolve the underlying constitutional question on the merits.