New York, New Haven & Hartford Railroad v. United States

Background

A railroad company sued the United States to recover the difference between what it was paid by the Post Office Department and what it says it should have received for carrying the mails during several years ending June 30, 1914. The company said implied contracts arose because it accepted and transported mail relying on § 4002 of the Revised Statutes, and because it did so under orders and pressure from the Post Office yet was not paid reasonable compensation.

Reasoning

The Court examined whether the Post Office incorrectly interpreted § 4002 by fixing payments for each four‑year term using weights taken just before the term began instead of measuring weights every year. The Court found this prior practice was permitted by the statute, the carrier accepted it with full knowledge, and earlier decisions supported that construction. The Court also explained that before the 1916 law most railroads were not legally required to carry the mails, so doing so voluntarily prevents a claim that the government unlawfully took property without paying full value. The Court of Claims had dismissed the petition, and the Supreme Court affirmed that dismissal.

Real world impact

The ruling means rail carriers who accepted the Post Office’s longstanding mileage-and-weight payment method cannot now demand larger retroactive payments for those years. It leaves the Post Office’s historical payment practice intact for the period at issue and closes this route to recovery for carriers. This decision is a final ruling on that petition.

Dissents or concurrances

One Justice, Justice Brandeis, dissented from the Court’s judgment.