CHI., B. & Q. RY. v. Wisconsin RR Com.
Headline: Court invalidates Wisconsin law forcing two daily passenger stops at small villages, limiting states’ power to require interstate trains to stop and protecting railroads from arbitrary schedule burdens.
Holding: The Court held that Wisconsin’s statute requiring fixed daily train stops at villages of 200 or more is invalid because it imposes arbitrary burdens on interstate rail traffic not tied to local transportation needs.
- Blocks states from forcing interstate trains into blanket stops at small villages.
- Requires regulators to base stop orders on local need, not automatic formulas.
- Protects railroads from arbitrary schedule burdens that would disrupt through connections.
Summary
Background
A Wisconsin resident asked the state railroad commission to require a railroad company to stop two passenger trains each way daily at the village of Cochrane, which had about 260 people and a post office. The state law required one daily stop at villages of 200 or more and two daily stops if four or more passenger trains were run each way. The commission ordered extra stops, the state courts affirmed, and the railroad challenged the law in the federal courts as an unreasonable burden on interstate traffic.
Reasoning
The Court focused on whether the statute’s fixed formula for stops unreasonably interfered with interstate rail service. It found that the railroad’s line was dominated by interstate travel, that trains were scheduled tightly to make connections, and that an automatic requirement based on village population and train counts ignored actual local needs. Because the law forced additional stops or extra trains without inquiry into local demand, it imposed arbitrary burdens on interstate commerce and was therefore invalid.
Real world impact
The ruling prevents states from using rigid formulas to force interstate trains to stop regardless of actual local conditions. State regulators may still order additional service after investigation, but they must tailor requirements to local needs and avoid imposing undue burdens on through traffic. The case was reversed and sent back for further proceedings consistent with this opinion.
Dissents or concurrances
A justice in the state court dissented, arguing that "convenience" is flexible and that legislatures should have broad discretion to decide what local service is reasonable.
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