Louisville & Nashville Railroad v. Maxwell
Headline: Court enforces filed interstate railroad fares, reverses state ruling, and lets carrier seek unpaid fare difference when tickets were sold below lawful tariff for chosen route.
Holding: The Court reversed, holding that the Interstate Commerce Act requires carriers to charge filed tariffs and permits recovery of unpaid differences when tickets were sold below lawful rates for the chosen route.
- Makes passengers responsible for filed ticket rates despite agent quotes.
- Allows railroads to recover unpaid fare differences from undercharged tickets.
- Requires further proof of the actual filed tariffs before final recovery.
Summary
Background
A man bought two round-trip railroad tickets from Nashville to Salt Lake City, asking to go one way by Chicago and Denver and return by a different route. He paid $49.50 per ticket, but the state court found the published fares for the actual route traveled totaled $78.65 each, creating an alleged undercharge of $58.30. The railroad sued in a local court to recover the difference; state appellate courts ruled for the passenger, and the case reached the United States Supreme Court.
Reasoning
The central question was whether the railroad could insist on the formally filed fare when its agent issued tickets at a lower price. The Court said the Interstate Commerce Act requires carriers to charge the tariff they filed and that passengers are charged with notice of those rates. The Court distinguished a wrong quoted price from a routing issue and rejected the state court’s view that the passenger could avoid the higher fare by traveling different routes at the lower price. Because the record did not include the actual tariffs, the Court reversed the state judgment but remanded so the parties could resolve whether the filed rates in fact supported the railroad’s claim.
Real world impact
The decision makes it clear that carriers may enforce filed fares and seek unpaid differences when tickets are sold below lawful rates. Travelers who rely on an agent’s lower quote may still be held to the posted tariff. Because the Court remanded for further fact-finding about the tariffs, the outcome could change if the filed rates later show no undercharge.
Dissents or concurrances
One Justice, McReynolds, dissented from the Court’s decision, indicating not all Justices agreed with the majority outcome.
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