International Railway Co. v. Davidson

Background

The dispute involved a private company that owns two toll bridges across the Niagara River and the Federal Collector of Customs acting under the Treasury Department. For over twenty years the Government kept customs inspectors at the American ends of the bridges day and night. In 1920 the Collector said that on Sundays and holidays vehicles (except trolleys) and passengers would be stopped unless the bridge company took a special license, paid overtime for inspectors, and posted a large indemnity bond.

Reasoning

The Court examined the 1911 statute and its 1920 amendment and focused on what Congress actually authorized. The statute created special licenses for the immediate lading or unlading of vessels and other conveyances, with rules about cargo, manifests, and entry. The amendment added overtime pay for examining passengers’ baggage but, the Court found, only in the context of vessels and immediate lading or unlading. The Court concluded the law did not reach a toll-bridge and that the Secretary of the Treasury had no authority to withdraw service or impose license, overtime, and bond requirements that amount to charging owners without explicit Congressional authorization.

Real world impact

The decision protects the bridge company’s weekend passenger traffic by preventing the Collector from cutting off customs service or making the company buy the special license and pay the added costs. It also clarifies limits on the Treasury’s power to shift inspection costs onto private operators without clear Congressional approval.