Wabash, St. Louis, and Pacific Railway Co. v. Illinois
"Wabash, St. Louis, and Pacific Railway Co. v. Illinois" is a landmark Supreme Court case from the late 19th century that addressed the balance of power between state regulation and federal authority over interstate commerce. The case arose from an Illinois law that aimed to regulate railroad rates by prohibiting price differences for long-haul versus short-haul routes. The Court ruled that such regulations imposed a direct burden on interstate commerce, thus infringing upon federal authority. This decision highlighted the complexities and inconsistencies faced by railroads operating across state lines during a period of rapid expansion and economic change.
The ruling prompted a significant legislative response, leading to the establishment of the Interstate Commerce Act of 1887. This act created the first independent federal regulatory agency tasked with overseeing the railroad industry and addressing issues of fair pricing and competition. The Wabash case thus not only shaped the legal landscape of the time but also marked a shift towards greater federal involvement in regulating commerce. Over the following decades, the approach to regulating commerce evolved further, with the Supreme Court eventually adopting a more nuanced balancing method. This case remains a pivotal moment in the history of U.S. commerce regulation and illustrates the ongoing tension between state and federal powers.
Wabash, St. Louis, and Pacific Railway Co. v. Illinois
Date: October 25, 1886
Citation: 118 U.S. 557
Issue: Regulation of interstate commerce
Significance: In striking down a state law regulating railroad pricing policies, the Supreme Court encouraged Congress to enact national standards.
During the second half of the nineteenth century, state legislatures used their police powers to regulate the intrastate commerce of railroads, and the railroads faced great confusion and inconsistencies as they crossed state lines. In 1852 the Supreme Court had ruled that states could enact indirect but not direct burdens on interstate commerce. In the Wabash case, the issue was an Illinois law that prohibited a difference between long-haul and short-haul rates, and the Court ruled that such rate regulations placed a direct burden on the federal commerce power. In response to the decision, Congress passed the Interstate Commerce Act of 1887, which established the first independent federal agency for regulating businesses. In the 1930’s, the Court gave up the direct versus indirect test in favor of a functional balancing approach.
