Wabash, St. Louis & Pacific Railroad Company v. Illinois
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Wabash, St. Louis & Pacific Railroad Company v. Illinois 118 U.S. 557 (1886), also known as the Wabash Case, was a United States Supreme Court case that severely limited the rights of states to control interstate commerce. It led to the creation of the Interstate Commerce Commission.
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The Bench
Opinion:
Associate Justice Miller
Concurring:
Associate Justices Field, Harlan, Woods, Matthews, and Blatchford.
Dissenting:
Associate Justices Bradley and Gray; Chief Justice Waite.
The Case
Wabash, St. Louis & Pacific Railway Co. v. People of State of Illinois, 118 U.S. 557 (1886), was argued on April 14, 1886-April 15, 1886 and was decided on October 25, 1886 by vote of 6 to 3. Associate Justice Miller wrote for the Court with Associate Justices Field, Harlan, Woods, Matthews, and Blatchford concurring; Associate Justices Bradley and Gray, along with Chief Justice Waite, dissented.
In Wabash, the Court had to decide on whether states have the power to regulate railroad rates for interstate shipments. It ruled that the Commerce Clause does not permit states to enact "direct" burdens on interstate commerce (noting, however, that "indirect" burdens were permitted under the Commerce Clause). This was a significant departure from the accepted standard enacted in Cooley v. Board of Wardens (1852).
It should be noted, however, that Wabash did not strip states of all power to regulate interstate railroads. For example, the state safety regulations remained as allowed "indirect" burdens. However, prior to Wabash, the federal government yielded the subject of railroad regulation to the states; Wabash made rate regulation of shipments between states a protected federal power.
Spurred by this decision, Congress established the Interstate Commerce Commission in 1887, the first regulatory agency. Wabash can thus said to have led to the creation of the modern regulatory agency and signaled the movement of the national government to assume responsibility for economic affairs which was previously delegated to the states.
Effects of Decision
- The Wabash decision led to the creation of the first modern regulatory agency, the Interstate Commerce Commission.
- It clarified the "direct" v. "indirect" test (though this doctrine was abandoned in the 1930s).
- It was one of the first instances in government assuming responsibility for economic affairs that had previously been delegated to the states.
See also
External Links
- Full decision and opinions in Findlaw.com (http://caselaw.lp.findlaw.com/scripts/getcase.pl?navby=search&court=US&case=/us/118/557.html)
- Supreme Court cases citing Wabash (http://caselaw.lp.findlaw.com/scripts/casesearch.pl?court=us&CiRestriction=118+u.s.+557&)
- Case summary from Bartleby.com (http://www.bartleby.com/65/wa/WabashCa.html)