Southern Pacific R. Co. v. Arizona
Court upholds Arizona regulator’s order forcing a railroad to carry a carnival from Tucson to Phoenix at a special intrastate rate, rejecting the railroad’s interstate-commerce challenge and affirming the fine.
Holding
The Court held that the Tucson–Phoenix movement was not in interstate commerce when the state order issued, so the commission’s intrastate rate order and contempt fine were valid.
Real-world impact
- Allows state regulators to set intrastate railroad rates for local shipments.
- Makes it harder for railroads to avoid state orders by asserting future interstate plans.
- Upholds fines when a railroad disobeys a lawful state rate order.
Topics
Summary
Background
An agent for a traveling carnival asked a railroad to move eighteen cars of equipment, employees, and animals from Tucson to Phoenix. The railroad refused, saying it had an earlier contract and would only carry the show at its high published interstate rates. The Arizona Corporation Commission ordered a special intrastate rate and customary contract terms. The railroad disobeyed, was held in contempt, fined $1500, and the State sued to collect the fine. The railroad argued the trip was part of an interstate tour beginning in El Paso and thus beyond state control.
Reasoning
The Court considered whether the Tucson–Phoenix movement was actually part of interstate transportation when the commission issued its order. The record showed the show was exhibiting in Tucson for six days and no contract for travel beyond Phoenix existed at the time of the order. Later contracts to continue the tour were made weeks afterward with another railroad. The Court concluded that mere plans to travel across state lines do not make a present intrastate trip interstate. Because the shipment was not then in interstate commerce, the state’s order and the contempt fine were valid.
Real world impact
The ruling confirms that state regulators may require railroads to accept reasonable intrastate rates for local moves that are not presently part of interstate transportation. A shipper’s future travel plans do not automatically block state regulation of a local segment. The judgment of the Arizona courts was therefore affirmed.
Questions, answered
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