Chicago, Milwaukee & St. Paul Railway Company v. Minnesota
Encyclopedia
Chicago, Milwaukee & St. Paul Railway Company v. Minnesota, 134 U.S. 418 (1890), was a case in which the Supreme Court of the United States
held that procedural due process
limits state regulatory power over railroad rates. A regulatory agency in Minnesota had set railroad rates that the Minnesota Supreme Court
had refused to overturn. The U.S. Supreme Court found that the rates were set without due process of law, specifically without an opportunity to challenge the equality and reasonableness of the charges. The Minnesota court had sanctioned rate-setting without any judicial hearing, requirement of notice or witnesses, "-in fact, nothing which has the semblance of due process of law".
The court rejected the railroad's argument that the state's contract with the Minnesota railroad line, as it existed in prior state-chartered companies that the railroad later bought, remained in force against state law. Instead, they found that the state's right to regulate industry could not be forfeited except by an explicit declaration in law. However, this issue was subsumed by the court's broader decision regarding due process.
Justice Bradley strongly dissented from the decision, indicating that it practically overturned Munn v. Illinois
and other railroad cases that left states to decide toll rates. He indicated that it was the provence of the states to decide the policy question of railroad rates, and not that of the judiciary.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that procedural due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
limits state regulatory power over railroad rates. A regulatory agency in Minnesota had set railroad rates that the Minnesota Supreme Court
Minnesota Supreme Court
The Minnesota Supreme Court is the highest court in the U.S. state of Minnesota and consists of seven members. The court was first assembled as a three-judge panel in 1849 when Minnesota was still a territory. The first members were lawyers from outside of the region who were appointed by...
had refused to overturn. The U.S. Supreme Court found that the rates were set without due process of law, specifically without an opportunity to challenge the equality and reasonableness of the charges. The Minnesota court had sanctioned rate-setting without any judicial hearing, requirement of notice or witnesses, "-in fact, nothing which has the semblance of due process of law".
The court rejected the railroad's argument that the state's contract with the Minnesota railroad line, as it existed in prior state-chartered companies that the railroad later bought, remained in force against state law. Instead, they found that the state's right to regulate industry could not be forfeited except by an explicit declaration in law. However, this issue was subsumed by the court's broader decision regarding due process.
Justice Bradley strongly dissented from the decision, indicating that it practically overturned Munn v. Illinois
Munn v. Illinois
Munn v. Illinois, 94 U.S. 113 , was a United States Supreme Court case dealing with corporate rates and agriculture. The Munn case allowed states to regulate certain businesses within their borders, including railroads, and is commonly regarded as a milestone in the growth of federal government...
and other railroad cases that left states to decide toll rates. He indicated that it was the provence of the states to decide the policy question of railroad rates, and not that of the judiciary.