Minneapolis, St. Paul & Sault Ste. Marie Railway Co. v. Washburn Lignite Coal Co.

Background

A railroad company carried many carloads of coal within North Dakota and charged the maximum rates that the State had set and the carriers had filed publicly. The State had earlier obtained court orders (injunctions) forcing carriers to use that published schedule while litigation over the schedule continued. The railroad later sought extra payment for shipments made while the injunctions were in force, saying the posted rates were confiscatory and later declared insufficient.

Reasoning

The central question was whether the railroad could collect additional compensation for past shipments after having charged and accepted the published maximum rate while a court order required it to follow that schedule. The state supreme court found there was no contract letting the shipper pay more, noted the injunctions had been issued without bond or special terms, and rejected unjust-enrichment relief because the shipper was no more at fault than the carrier. The U.S. Supreme Court held that those independent state-law grounds supported the state judgment and therefore the carrier’s federal constitutional claim did not provide a proper basis for review, so the Court dismissed the railroad’s challenge.

Real world impact

The outcome leaves in place the state-court rulings that prevent the railroad from recovering extra sums for shipments where the published tariff was charged and accepted under a court order. Shippers who paid the posted maximum rate are protected by the decision. The dismissal rests on how the state court decided the case, not on a new national constitutional ruling, so the result is limited to these facts.