Louisville & Nashville Railroad v. United States

Background

A railroad company that included two lines built with Federal land grants sued the United States to recover higher fares. The land-grant acts said railroads must be free from tolls for transport of any property or troops of the United States. For routes covered by those acts, the Government pays half the private rate. The company claimed the Treasury had applied the lower land-grant rate to certain transported people who were not “troops,” while the company said they were entitled to full pay. The Court of Claims dismissed the suit, and the railroad appealed.

Reasoning

The central question was whether members of the Coast Guard count as “troops” under the land-grant laws. The Coast Guard was created in 1915 from the Revenue-Cutter Service and Life-Saving Service and was declared “a part of the military forces of the United States.” The statute also says the Coast Guard operates under the Treasury in peacetime but under the Navy in wartime or on the President’s direction. The Court held that “troops” is not limited to land forces and includes members of every branch. Thus Coast Guard members are troops when serving as part of the Navy, but not when operating under the Treasury and paid by that Department.

Real world impact

Because the lower court’s findings did not say whether the questioned transport happened before the April 6, 1917 declaration of war, the Supreme Court sent the case back for a new factual finding. If the disputed Coast Guard trips occurred before the declaration of war, the railroad may recover the unpaid balance for those prewar transports. Otherwise the Court left the lower court’s decision intact.