Chicago, Burlington, and Quincy Railroad Co. v. Chicago
"Chicago, Burlington, and Quincy Railroad Co. v. Chicago" is a significant Supreme Court case that addressed the application of the Fourteenth Amendment's due process clause in relation to property rights. The ruling stemmed from a dispute where the Chicago, Burlington, and Quincy Railroad objected to the city of Chicago's construction of a street that interfered with its railroad tracks, resulting in a minimal compensation verdict of one dollar awarded by the Illinois Supreme Court. The Supreme Court unanimously ruled that states are required to provide just compensation when private property is taken for public use, affirming the incorporation of the Fifth Amendment's protections at the state level. This case is notable for its early exploration of substantive due process, influencing future legal interpretations regarding economic regulation and property rights. While the broader implications of the case have evolved, it remains a key reference point in discussions about the relationship between state actions and constitutional guarantees. The decision illustrates the ongoing balance between governmental authority and individual rights in the context of public policy and economic interests.
Chicago, Burlington, and Quincy Railroad Co. v. Chicago
Date: March 1, 1897
Citation: 166 U.S. 226
Issues: Incorporation doctrine; substantive due process
Significance: The Supreme Court held that the due process clause of the Fourteenth Amendment applied to the states and that, therefore, the state needed to compensate a railroad adequately when it converted private property to a public purpose.
Justice John Marshall Harlan wrote the 7-1 majority opinion with Justice David J. Brewer dissenting in part and Justice Melville W. Fuller not participating. The Supreme Court unanimously held that the Fourteenth Amendment’s due process clause required the states to grant just compensation when it took private property for a public purpose. The ruling was unanimous because Justice Brewer concurred on this point even though he dissented on other issues.
The Illinois supreme court had upheld a jury verdict of one dollar awarded to the Chicago, Burlington, and Quincy Railroad for loss of its money-making ability when the city of Chicago created a street across its railroad track. Chicago, Burlington, and Quincy Railroad Co. was one of the earliest attempts to use the right of substantive due process to control a state’s attempt to regulate economic behavior. Although this latter purpose has been set aside by other decisions, this case remains valid law for the proposition that the Fourteenth Amendment due process clause incorporates specific guarantees for the Bill of Rights. In this case, the Fifth Amendment’s guarantee of just compensation when private property is taken for public purpose was incorporated and applied to the states.