Mich. Cent. RR Co. v. Mich. RR Comm.

Background

The dispute involved the Michigan Central Railroad, an interstate steam railroad operating through Oxford, and the Detroit United Railway, an interurban electric line running from Detroit to Flint and through Oxford. Merchants in nearby Ortonville and Goodrich asked the state railroad commission in 1908 to require a physical track connection at Oxford so cars, carload and less-than-carload freight, and passengers could be interchanged. The Commission found a connection practicable (about $500), that the Detroit United was standard gauge and capable of handling freight cars, and ordered the two companies to connect and interchange. The connection was built, but Michigan Central refused to deliver loaded cars to the Detroit United, prompting a mandamus action enforced by the Michigan Supreme Court limited to intrastate traffic.

Reasoning

The core question was whether the state could lawfully require a physical connection and the interchange of cars for intrastate business without violating the Constitution. The United States Supreme Court affirmed the state court, relying on statutory provisions (1907 and 1909 acts) and precedent allowing reasonable state regulation of carriers for public benefit. The Court held the order applied to intrastate traffic only, was practicable, provided for reasonable compensation and protections, and did not unlawfully take property or improperly burden interstate commerce as reasonably construed and limited.

Real world impact

As a result, the Michigan Central must permit interchange at Oxford for intrastate freight and passengers under the conditions approved by the Commission. Local merchants and towns served by the Detroit United stand to gain improved freight and passenger service. The decision also reinforces that state regulators can require reasonable physical connections and car interchange for intrastate transportation when supported by findings and statutory safeguards.