United States v. Nixon

Background

A federal grand jury indicted the St. Louis & San Francisco Railroad Company’s receivers, saying they carried cattle on August 16, 1913 from an Oklahoma quarantine district to Kansas City without following rules set by the Secretary of Agriculture. The indictment’s caption referred to sections of the 1905 quarantine law that penalized railroad companies for moving cattle from quarantine States without complying with regulations. The receivers filed a demurrer, and the trial court sustained it, reasoning that under a prior decision the 1905 statute did not make receivers criminally liable.

Reasoning

The central question was whether any federal statute made receivers who operate a railroad criminally responsible for transporting quarantined cattle without following federal rules. The Court explained that Congress in 1913 amended the quarantine law to make its penalties apply to any railroad company or other common carrier, explicitly including roads operated by receivers. Because the lower court treated the indictment only under the 1905 law and overlooked or misconstrued the 1913 amendment, its dismissal was a legal construction the Criminal Appeals Act allowed the Supreme Court to review. The Court held the indictment did allege conduct falling within the amended statute and reversed the judgment.

Real world impact

The result means receivers who run railroads can be criminally charged if they move cattle from quarantine areas without following Agriculture Department regulations. The ruling removes a legal shield that had been thought to protect receivers from this specific penalty, and it clarifies that Congress expanded coverage in 1913. The reversal returns the case to lower court procedures for prosecution.

Dissents or concurrances

One Justice, McReynolds, took no part in the consideration and decision of the case.