Lake Erie & Western Railroad v. State Public Utilities Commission Ex Rel. Cameron
Headline: Court upholds state order forcing railroad to restore a public side track serving a grain elevator, allowing shippers access while preserving the railroad’s ownership and ability to charge reasonable fees.
Holding: The Court held that a state commission may order a railroad to restore a public-use side track without violating the Fourteenth Amendment because the track remains public and the railroad keeps ownership and may charge reasonable rates.
- Requires railroad to restore public side track serving local shippers.
- Allows the railroad to keep ownership and charge reasonable fees for use.
- Holds the order is not a taking under the Fourteenth Amendment.
Summary
Background
For twenty-five years a railroad maintained a side track at Elliott, Illinois, that passed a grain elevator and coal yard operated by a man named Cameron. The elevator once stood partly on the railroad’s right of way under a lease. In May 1915 the elevator burned, the railroad canceled the lease and removed the side track. Cameron rebuilt on his own land and in June 1915 asked the state Public Utilities Commission to order the track restored. The commission and the state courts granted that request.
Reasoning
The core question was whether the state order violated the Fourteenth Amendment by taking the railroad’s property for private use or for public use without compensation. The Court explained that under state law the side track had been open for public use and was treated as having a public character. The statute that authorized the restoration also kept the track available to other shippers. The commission found the expected business justified repair, noted past yearly shipments of about $20,000, and the Court concluded the order did not improperly take the company’s property because the company retains ownership and may make reasonable charges.
Real world impact
The ruling leaves the state able to require restoration of tracks that serve the public and local shippers. The railroad must restore the track but keeps ownership and the right to charge reasonable fees. The opinion affirms the state process and does not find a constitutional taking on these facts.
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