Pennsylvania Railroad v. Towers
Headline: Court upholds state commission’s power to require a railroad to sell intrastate commutation tickets at fixed rates, allowing reduced suburban fares and limiting a railroad’s freedom to abandon established commuter rates.
Holding: The Court held that a State public service commission may require a railroad to maintain intrastate commutation rates that the railroad itself had voluntarily established, and that enforcing those rates does not violate the Fourteenth Amendment.
- Allows states to require railroads to keep commuter fares they established.
- Protects suburban commuters who rely on reduced commutation tickets.
- Limits a railroad’s ability to withdraw special commuter fare practices.
Summary
Background
This dispute involved a railroad company (the Pennsylvania Railroad, lessee of the Northern Central Railway) and the Maryland Public Service Commission. The Commission ordered the railroad to sell intrastate commutation tickets between Baltimore and Parkton at specified rates. The railroad asked a Maryland court to block enforcement, arguing the order would take its property without due process, discriminate against interstate travel, and otherwise be unreasonable. The Maryland courts refused relief and the state appellate court affirmed.
Reasoning
The central question was whether a State commission may require a carrier to maintain commutation rates that the carrier itself had voluntarily established. The Court said yes for wholly intrastate fares. It explained commutation tickets are a different kind of service than single-trip or mileage tickets, involve different costs, and have supported suburban communities. The opinion distinguished a prior case that had struck down mileage-book laws and said that the earlier decision does not prevent states from fixing reasonable commutation fares once a carrier has adopted them. The Court therefore upheld the commission’s authority and found no constitutional violation.
Real world impact
The ruling means States can use commissions to set and preserve special commuter fares when carriers have already created those fares. Thousands of suburban riders who rely on commutation tickets and the communities built around such service may keep protections for those fares. Railroads will have less freedom to unilaterally withdraw established commuter-rate systems.
Dissents or concurrances
Three Justices (the Chief Justice, Mr. Justice McKenna, and Mr. Justice McReynolds) dissented. The opinion does not detail their reasoning in the text provided.
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