Missouri, Kansas & Texas Railway Co. v. Texas

Background

The State of Texas sued a railroad company to collect penalties for violating a state railroad commission order. The order required passenger trains in Texas to depart from their origin and stations according to the advertised schedule, allowing up to thirty minutes at starting points or junctions to make connections and up to ten additional minutes if connecting trains were in sight. The trains at issue were parts of a through interstate movement whose cars originated in St. Louis and Kansas City and were taken over by the defendant at Denison, Texas, under a contract with another railroad. Lower courts found breaches of the order and imposed a fine.

Reasoning

The central question was whether the State Commission could apply this scheduling rule to trains that were part of interstate commerce. The Court acknowledged that the trains were instruments of interstate commerce but concluded that applying the state order in this case unlawfully interfered with that commerce. The order tried to fix how long a train could stop during an interstate transit, and it would hold the defendant responsible when a connecting interstate train from another company and another State caused the delay. The Court found that forcing compliance by, for example, running an extra train was impractical and would not excuse liability. For those reasons the state order, as applied to the interstate movement, exceeded the State’s power and the judgment imposing the fine was reversed.

Real world impact

Railroads moving cars across state lines cannot be held liable under this kind of state schedule rule when delays are caused by out-of-state connecting trains. The decision limits state commissions’ power over interstate train operations and prevents similar fines.