United States v. Northern Pacific Railway Co.

Background

The dispute involved the Northern Pacific Railway Company and the United States over two transfer trains that ran in September 1916 on a four-mile terminal railroad along the Duluth waterfront between Rice’s Point and Furnace. One train had a locomotive and forty-eight cars; the other had a locomotive and forty cars. The company said the short terminal road was not a main line, that trains there were not run like main-line trains, and that most switching and car assembly happened at larger yards at Rice’s Point and Furnace. The track includes single-track stretches, five grade crossings with other rail lines, and crossings of city streets and streetcars, and other independent rail companies also run or use parts of the line.

Reasoning

The central question was whether the federal Safety Appliance Act (a law requiring that train brakes be coupled so they can be controlled from the locomotive) applied to these transfer trains on the terminal road. The Court looked at the statute’s language that covers “all trains . . . used on any railroad engaged in interstate commerce,” noted that transfer trains qualify as “trains,” and explained that a moving locomotive with cars is not exempt unless the operation is mere switching or classifying inside yards. Given that the road was used in interstate commerce and the transfer trains ran solid between Rice’s Point and Furnace, the Court concluded the Act applied and reversed the Circuit Court of Appeals.

Real world impact

The decision requires railroads operating similar terminal lines used in interstate commerce to comply with the Act’s brake-coupling rule for transfer trains. The Court declined to balance particular dangers itself and applied the statute’s clear terms, leaving rail carriers responsible for meeting the law’s safety command.