Great Northern Railway Co. v. Minnesota Ex Rel. State Railroad & Warehouse Commission
Headline: Court blocks state commission’s order forcing a railroad to build a six‑ton livestock scale at a small town, ruling the mandate arbitrary and improperly requiring the company to spend or give up private property.
Holding: The Court held that the state commission could not compel the railroad to install a six‑ton stock scale at Bertha because the requirement was arbitrary, unrelated to the carrier’s transportation duties, and could be addressed by less burdensome measures.
- Prevents state regulators from forcing railroads to build nonessential private conveniences.
- Requires regulators to try less costly ways to fix discrimination.
- Protects railroad property rights against arbitrary administrative orders.
Summary
Background
A state railroad commission ordered the Great Northern Railway to build a six-ton stock scale at its station in Bertha, Minnesota. The railway already had similar scales at 54 of its 259 Minnesota shipping stations. Those scales were used by dealers and stock raisers before sale for convenience, but not for freight charges or transactions with the railroad. The Minnesota Supreme Court sustained the commission’s order, and the railway brought the case to the United States Supreme Court.
Reasoning
The Court considered whether forcing the railroad to install the scale would take property without due process. The Court found the scales were conveniences for buying and selling livestock, not part of the carrier’s transportation duties. Applying prior decisions, the Court said an order that effectively takes property must be justified by public necessity and not be arbitrary. Because the scales had no direct relation to transportation and because the commission could have stopped the alleged discrimination by ending use of existing scales, forcing new construction was arbitrary and unreasonable, so the Court reversed.
Real world impact
The decision protects the railroad from being required to build private conveniences that are unrelated to its transportation duties. It limits state regulators’ power to compel costly construction when less burdensome options exist. The case was reversed and sent back for further proceedings consistent with this opinion, allowing the commission to pursue other remedies to address any discrimination.
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